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Transfer pricing post Chevron paper


This paper covers:

  • introduction and Chevron background
  • Chevron - key observations
  • outstanding questions
  • which currency.

Author profiles

Julian Humphrey CTA
Julian, CTA, is a Partner of KPMG’s Banking and Finance practice with over 18 years experience. He works primarily with international banks and financial services companies operating in Australia, providing corporate income tax and more recently transfer pricing services. Julian’s areas of expertise include the taxation of banks and bank branches, the taxation of financial arrangements and retail financial products as well as Australia’s offshore banking regime. He has advised on a number of major M&A transactions in the financial services sector in recent years. He is currently heavily involved in the base erosion and profit shifting debate, working with clients to implement country-by-country reporting. He is a regular participant in consultation with the government on Australia’s tax reform proposals affecting Australian financial institutions. - Current at 17 March 2016
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Tim Keeling
Tim is a Director in KPMG’s international tax advisory practice. He has over 12 years’ of transfer pricing experience including in financial services and financial transactions. During Tim’s transfer pricing career, Tim has worked for both the Australian Taxation Office and professional advisory firms. - Current at 12 March 2018


This was presented at 2018 Financial Services Taxation Conference .

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Individual sessions

M&A in financial services

Author(s):  Paul ABBEY,  Jeanelle MENEZES

Materials from this session:

Residence – Central management & control

Author(s):  Stuart Dall,  Bob Deutsch,  Richard EVANS

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The ATO’s approach to significant financial services tax issues

Author(s):  Jeremy HIRSCHHORN

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Macro economic outlook and implications for taxation

Author(s):  Shane Oliver

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Australia’s hybrid mismatch rules: Application and interactions


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Tax transparency initiatives – The current state of play

Author(s):  Chris Vanderkley,  Helen Kelly

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Stapled groups

Author(s):  Andrew Hirst

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