shopping_cart

Your shopping cart is empty

  • Home
  • Baseball playbook - MLI, MAP and mandatory binding arbitration paper

Baseball playbook - MLI, MAP and mandatory binding arbitration paper

Member Price: $57.00
Non Member Price: $75.00

DisclaimerThis material is copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

Published on 11 Nov 20 by NATIONAL DIVISION, THE TAX INSTITUTE

This paper covers:

  • how arbitration works, with a focus on the final offer model adopted under most of Australia's DTAs, also known as the 'baseball' model
  • how taxpayers get to arbitration, and whether the prospect of arbitration can be expected to affect MAP
  • the tensions and complex decision making required in balancing domestic procedures for resolution with resolution achieved through MAP or arbitration
  • international experiences in tax arbitration.

Author profile

Martin Fry FTI
Martin Fry, FTI, is the Practice Leader of the Allens Tax Group. With over 20 years as a Partner of Allens, Martin advises corporations on a broad range of tax issues across a wide range of sectors, including resources, infrastructure, financial services and IP-intensive businesses. In recent years, Martin has focused on contentious transfer pricing matters, including audits, settlement negotiations, mutual agreement procedure and litigation. Martin has taught Corporate Tax at a postgraduate level at the University of Melbourne. - Current at 12 May 2021
Click here to expand/collapse more articles by Martin FRY.

 

This was presented at 2020 National Resources Tax Conference Online .

Get a 20% discount when you buy all the items from this event.

Individual sessions

Keynote address – Economic update

Author(s):  Noel Richards

Materials from this session:

What Directors are looking for from a tax risk management perspective

Author(s):  Teresa DYSON,  Michael Carey

Materials from this session:

Labour costs related to the construction or creation of capital assets

Author(s):  Marcus RYAN,  David WOOD

Materials from this session:

Decommissioning offshore petroleum project infrastructure - Regulatory and tax issues in the path forward for Australia

Author(s):  Jane Ballard,  Tristan Boyd

Materials from this session:

Australia's anti-hybrid rules for the sector

Author(s):  Amelia Teng

Materials from this session:

Australian corporate tax residency

Author(s):  Mathew CHAMBERLAIN

Materials from this session:

Topical issues and developments in M&A

Author(s):  Enzo COIA,  Cameron BLACKWOOD

Materials from this session:

Tax transparency

Author(s):  Damien Williams

Materials from this session:

The energy transition

Author(s):  O'Hare Janelle

Materials from this session:

Baseball playbook - MLI, MAP and mandatory binding arbitration

Author(s):  Martin FRY

Materials from this session:

Further details about this event:

 

Copyright Statement
click to expand/collapse