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The Commissioner’s transfer pricing powers and thin capitalisation safe harbours presentation


This presentation covers:

  • transfer pricing
  • Division 820
  • results under different ATO documents
  • effects of potential ATO adjustments
  • Division 13
  • associated enterprise article.

Author profile

Toby Knight CTA
Toby is a Tax Partner at Allens. He practises in corporate and international tax with particular expertise in dispute resolution, audits, transfer pricing, research and development, and tax litigation. He advises on mutual agreement procedures, tax treaty and structuring issues in transfer pricing matters and has over 17 years of experience in acting for many leading companies in a wide range of significant audits and tax litigation. These have included disputes in relation to capital gains tax, complex restructures and tax consolidation, Part IVA, foreign exchange transactions, franking credits and the application of different transfer pricing methodologies. - Current at 13 November 2013
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This was presented at Challenges to Funding Structures: Are you at risk? .

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Individual sessions

Certainty in the current tax funding market

Author(s):  Braedon CLARK

Materials from this session:

The Commissioner’s transfer pricing powers and thin capitalisation safe harbours

Author(s):  Toby KNIGHT

Materials from this session:

Practical implications and observations from a transfer pricing perspective

Author(s):  Garrick ROBINSON,  Chris THOMAS

Materials from this session:

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