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

More by Stephen BRECKENRIDGE

• Recent transfer pricing developments seminar paper - 22-September-2004
• Transfer pricing process seminar paper - 11-March-2003

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