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Transfer pricing and the Chevron case paper

Published on 02 Mar 16 by NATIONAL DIVISION, THE TAX INSTITUTE

This paper covers:

  • overview of the Chevron case
  • Division 13
  • Subdivision 815-A
  • whether the Associated Enterprises article in Australia’s DTAs is a stand-alone taxing power?
  • potential implications for taxpayers
  • recent OECD and ATO developments in relation to cross-border financing arrangements.

Author profile

Damian Preshaw CTA
Damian Preshaw, CTA, is a transfer pricing specialist with more than 25 years’ experience in both the private sector and with the ATO, and consults to accounting firms and law firms. Prior to establishing Damian Preshaw Consulting Pty Ltd in October 2015, Damian was a director in KPMG’s Transfer Pricing Services Group in Melbourne for 12 years. In this capacity, Damian advised a wide variety of multinational clients on transfer pricing and profit attribution issues with a special focus on dispute resolution, financial services, financial transactions and business restructuring. - Current at 24 July 2019
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