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Transfer pricing - current hot spots

Published on 14 Oct 99 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This presentation focuses on an Overview of the ATO's RRIP initiative, problems with comparability of data, advance pricing arrangements, penalties, and future directions. It outlines : Recent important ATO Transfer Pricing Rulings; Increased emphasis and development of Schedule 25A questions; Available TPM's; Extent of written documentation; Risk of ATO audit; Document enforcement; Major RRIP experiences; Controversial transfer pricing activity; "Commercial realism"; ABS data; ABS versus ATO statistics; Advance Pricing Arrangements; Penalties; and Ralph Business Tax Reform Recommendations.

Author profile:

Stephen Breckenridge
Prior to joining Baker & McKenzie, Stephen was the Director - International Tax in a second tier accounting firm. Stephen carried on a specialist corporate tax and transfer pricing practice in his own right for two and a half years, immediately after retiring in 2001 from KPMG where he was a tax partner for 24 years, specialising in transfer pricing. Current at 09 August 2004 Click here to expand/collapse more articles by Stephen BRECKENRIDGE.
 

This was presented at International Tax Masterclass.

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