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The reconstruction provision in the new Australian transfer pricing rules paper


This paper covers:

  • effect of tax treaties on the operation of the reconstruction provision
  • the "form" and "substance” of commercial or financial relations between entities
  • what would independent parties dealing wholly independently have done?
  • how do reconstructed transactions affect the calculation of tax payable?
  • does section 815-140 rely on the operation of the reconstruction provisions in cases of excessive debt?

Author profile:

Ian Fullerton CTA
Ian is a Consultant in the Tax group of Ashurst in Sydney. He joined the firm in 2012 after 14 years in group tax and institutional banking roles at two major Australian banks. At Ashurst, Ian advises on the tax aspects of a range of banking and corporate activities and has been involved with industry submissions on various cross-border tax issues, including the operation of the new transfer pricing rules. He is an author of the Thomson Reuters Australian Tax Handbook with responsibility for chapters on debt and equity, financial transactions, asset financing, trusts and tax planning and he is the author of the Tax chapter in Ford & Lee: The Law of Trusts. Current at 15 October 2014 Click here to expand/collapse more articles by Ian FULLERTON.

This was presented at 2015 Financial Services Taxation Conference.

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