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Practical application of the diverted profits tax provisions paper


This paper covers:

  • overview of the DPT 
  • practical issues in application of DPT.

Author profiles

Antony Faisandier
Antony is a Senior Manager at PwC. - Current at 25 June 2018
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Angela Danieletto CTA
Angela Danieletto, CTA is a Partner in PwC's international tax group in Sydney. Angela has over 15 years’ experience advising across all aspects of corporate and international tax, with a particular focus on cross border structuring, M&A and real estate. Angela joined PwC in 2013 and previously worked for a top-tier law firm. - Current at 24 July 2018
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Peter Algar
Edwin Baghdasarayan ATI
Edwin is a Transfer Pricing Partner within the PwC Australia Global Tax practice, based in Sydney. He has practiced transfer pricing at PwC since 2007 and has been involved in assisting numerous Australian, US and NZ top listed multinationals in their global transfer pricing across the entire lifecycle including consulting, structuring and planning, documentation, managing risk reviews, audits and unilateral/bilateral APAs. His experience ranges across a variety of industries, including financial services, consumer & industrial products, resources, logistics/transport and the technology sector. In particular, he has extensive experience in transfer pricing consulting for financial transactions, including funding across various industries and corporate purposes, financial instruments (e.g., options, swaps & forwards), cash pooling, guarantee fees and thin capitalisation/debt characterisation. As part of this experience, he has actively contributed to financial transactions transfer pricing thought leadership within both the US and the Asia Pacific region including drafting publications, leading presentations and various other policy initiatives. - Current at 22 October 2020
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Carynne Howitt


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