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TH10 tax disputes/litigation in the transfer pricing context presentation

Published on 14 Sep 11 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This presentation covers:

  • transfer pricing in Australia
  • Australian transfer pricing cases
  • Roche Products Pty Ltd v Comr
  • SNF (Australia) Pty Ltd v Comr
  • legal and practical implications - Q&A.

Author profiles:

Author Photo - Pete Calleja
Pete Calleja
Pete Calleja is a Partner in the transfer pricing practice of PwC Sydney and also currently leads the PwC Asia Pacific transfer pricing practice. He has more than 13 years of tax and transfer pricing experience and has conducted a wide variety of complex cross-border business transformation projects, successfully agreeing numerous multilateral Advance Pricing Agreements (APA) and resolving TP disputes through the Mutual Agreement Procedure (MAP) process. Current at 01 March 2012 Click here to expand/collapse more articles by Peter Callejah.
 
Author Photo - Paul McNab CTA
Paul McNab CTA
Paul is a Partner and solicitor in the Tax Controversy practice in PwC Sydney. Paul has more than thirty years of taxation experience and has published and spoken on a wide range of taxation issues throughout that period. Over the last 20 years he has had extensive experience in assisting clients understand the tax risks they face and manage their interactions with the ATO. His client base includes some of Australia and the world's largest multinationals and the information technology and telecommunications sectors are particularly heavily represented. His work has included planning for and review of significant transactions (including business value chain transformations), assistance with the assessment and disclosure of tax risk to statutory auditors, management of audits by the ATO and negotiation of settlements and the preparation and conduct of litigation. Current at 01 April 2015 Click here to expand/collapse more articles by Paul MCNAB.

This was presented at International Masterclass.

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