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Transfer pricing and the Chevron case presentation
Published on 02 Mar 16 by NATIONAL DIVISION, THE TAX INSTITUTE
This presentation covers:
- overview of credit facility (the loan transaction)
- overview of Chevron’s and Commissioner’s cases
- why did Commissioner argue loan was in USD rather than AUD?
- Division 13 - issues considered
- Subdivision 815-A - issues considered
- is Article 9 a stand-alone taxing power?
- potential implications for taxpayers
- OECD developments
- ATO developments.
Author profile
Damian Preshaw CTA
Damian Preshaw is a transfer pricing specialist with more than 25 years’ experience in both the private sector and with the Australian Taxation Office and provides specialist transfer pricing services to accounting firms and law firms. Prior to establishing Damian Preshaw Consulting Pty Ltd, 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. Before joining KPMG, Damian was an international tax counsel in the ATO’s Transfer Pricing Practice in Canberra where he was extensively involved in the ATO’s transfer pricing rulings program and was an Australian delegate to the OECD’s Working Party No.6 (Taxation of Multinational Enterprises) from 1994 to 2003. Damian is a Chartered Tax Adviser and represented The Tax Institute on the ATO’s Division 815 Technical Working Group. Damian has twice appeared as a witness before the Senate Economics Legislative Committee’s hearings in relation to Australia’s new transfer pricing rules on behalf of The Tax Institute. - Current at 09 July 2020
This was presented at 31st National Convention .
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Transfer pricing and the Chevron case
Author(s): Damian PRESHAWMaterials from this session:
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Employment taxes - Focus on FBT
Author(s): Elizabeth LUCASMaterials from this session:
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Tax issues for digital business
Author(s): Joanne DUNNE, Nathan Krapivensky, Antonella Schiavello, Hilary TaylorMaterials from this session:
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Practical issues - Case studies - Tax & insolvency
Author(s): Simon AITKENMaterials from this session:
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SMSF participation in private business
Author(s): Matthew AndruchowyczMaterials from this session:
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Best practice tax governance
Author(s): Sarah BlakelockMaterials from this session:
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The evolution of corporate taxation - A work in progress
Author(s): Ken SPENCEMaterials from this session:
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Small business CGT concessions selected practical issues
Author(s): Robert WARNOCKMaterials from this session:
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The very hungry (not-for- profit) caterpillar
Author(s): Adam LEVINMaterials from this session:
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CGT roll-overs - An SME’s perspective
Author(s): Stuart GlasgowMaterials from this session:
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Succession planning to avoid disputes between trustees & beneficiaries
Author(s): Sam McCulloughMaterials from this session:
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Recent developments in tax transparency
Author(s): Dr Michael DIRKISMaterials from this session:
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The trusted adviser as a gate keeper
Author(s): Ken SCHURGOTTMaterials from this session:
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An inbound investor’s feast
Author(s): Katrina PARKYN, Tim SHERMANMaterials from this session:
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ATO Taxation Office roundtable
Author(s): Gordon S COOPER, Kirsten FISH, Andrew MILLS, Cameron RIDERMaterials from this session:
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Digital and technological disruptors to your business - How to prepare for and manage them
Author(s): Peter WilliamsMaterials from this session:
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SMSF real property investments
Author(s): Stuart FORSYTHMaterials from this session:
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The private funding conundrum
Author(s): Darren Catherall, Greg NIELSEN, William O’SullivanMaterials from this session:
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Revisiting reimbursement agreements
Author(s): Jeffrey CHANGMaterials from this session:
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2016 National Convention Video Package
Author(s): Stuart FORSYTHMaterials from this session:
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