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Transfer pricing legislation reform - Tranche 2: What does it mean for tax payers presentation

Published on 16 May 13 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

What does the next round of proposed changes to the transfer pricing legislation mean for taxpayers?

  • ??interaction with other transfer pricing guidelines, legislation, treaties and OECD guidelines
  • ??increase in the ATO’s ability to re-characterise and/or unwind transactions??
  • similarities and differences to Part IVA
  • ??implications for the preparation of transfer pricing documentation and penalty protection??
  • action steps for taxpayers.

Author profiles:

Jesper SOLGAARD
Jesper is a Partner at Ernst and Young.
Click here to expand/collapse more articles by Jesper SOLGAARD.
 
Author Photo - Paul Balkus
Paul Balkus
Paul is the co-leader of Ernst & Young’s Oceania Transfer Pricing practice. He has over 20 years experience in the field of tax and transfer pricing including significant experience in servicing clients across most industries including financial services, mining and resources, pharmaceutical and fast moving consumer goods. Paul has been involved in all aspects of transfer pricing including advance pricing arrangements, dispute resolution, planning and documentation. More specifically, Paul’s experience has included addressing transfer pricing issues in connection with inter-company arrangements involving supply chain restructuring arrangements, global funds management, credit and performance guarantees, global trading and intercompany financing. Current at 02 June 2014 Click here to expand/collapse more articles by Paul BALKUS.

This was presented at NSW 6th Annual Tax Forum.

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The promoter penalties regime

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