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Transfer pricing aspects of insurance & reinsurance operations presentation


This presentation covers:

  • insurance industry:
    • caught in the cross-currents of TP law change, domestic and treaty ‘carve outs’, and increased scrutiny of risk transfers and ‘tax havens’ through OECD/G20 BEPS project
  • TP aspects of:
    • reinsurance arrangements
    • investment management activities
    • intra-group services
    • attribution of profits to insurance PEs
    • impacts of recent TP legislative changes & BEPS initiatives.

Author profiles

Geoffrey Gill ATI
Geoff is a transfer pricing partner with Deloitte based in Sydney. Geoff leads Deloitte Australia's transfer pricing practice for the financial services industry and also specialises in the analysis of financial transactions. He has advised on many APAs, audits and risk reviews including the first completed joint transfer pricing audit between the ATO and IRS. Recently, Geoff has been closely involved in working with the Australian Treasury on the reforms to Australia's transfer pricing rules. - Current at 01 November 2013
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Cameron (duplicate use 161916) Smith
Photo of author, Cameron Smith Cam is a Partner in Deloitte Melbourne's Transfer Pricing practice and has more than 18 years' transfer pricing and international tax experience, working in Australia, New Zealand and Europe. Cam's experience includes advising on a wide variety of complex transfer pricing matters for some of the world's largest multinational enterprises. - Current at 14 August 2013


This was presented at 2014 Financial Services Taxation Conference .

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