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Branch attribution paper

Published on 08 Feb 17 by NATIONAL DIVISION, THE TAX INSTITUTE

This paper covers:

  • timeline of key documents/events
  • current Australian law and ATO practice
  • RBA vs. AOA
  • international comparison
  • ATO focus areas in bank PE attribution
  • current practical issues and risks, including transfer pricing methodologies.

Author profile

Julian Pinson FTI
Julian Pinson, FTI, is a Partner at Greenwoods & Herbert Smith Freehills Pty Limited. Julian advises on a wide range of tax matters, with a focus on banking and financial services, property, M&A and funds management. Julian has particular expertise in cross-border finance, TOFA, corporate restructures, debt and equity raisings and M&A. - Current at 14 January 2021
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This was presented at 2017 Financial Services Taxation Conference .

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Recent cases and rulings

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Transfer pricing and financial services organisations

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Automatic exchange of information and the common reporting standard from the perspective of Australian financial institutions

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Division 6c

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Author(s):  Jeremy HIRSCHHORN

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Latest on the superannuation and related tax issues (large funds)

Author(s):  Bevan Grace

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Branch attribution

Author(s):  Julian PINSON

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BEPS for banks and insurance companies

Author(s):  Peter COLLINS,  Matt OSMOND,  Jayde THOMPSON

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The Board of Taxation

Author(s):  Ann-Maree Wolff

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