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Transfer pricing update paper


This paper covers:

  • compliance issues and the use of PCGs
  • justified trust initiatives
  • APA program status
  • other recent developments.

Author profiles

Michael Jenkins CTA
Michael joined the EY transfer pricing practice in November 2018 as an Associate Partner. Immediately prior to joining EY, Mr Jenkins was an Assistant Commissioner in the ATO, holding the position of the ATO’s Chief Economist and leader of the ATO’s APA/MAP unit, responsible for Australia’s competent authority program. Mr Jenkins has more than 20 years specialist experience in transfer pricing, and while at the ATO was heavily involved in the re-write of Australia’s transfer pricing rules (enacted 2013). He was also an Australian delegate to the OECD’s Working Party 6 on transfer pricing matters 2010-2018. - Current at 04 September 2019
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Jessica Uchida
Jessica Uchida joined EY in March 2009 and is a senior manager in the transfer pricing practice. She recently returned to Melbourne, having completed a four-year secondment with EY Japan’s Tokyo practice. Jessica has almost 10 years professional transfer pricing experience, supporting clients with transfer pricing and BEPS compliance, planning advice and controversy support. Jessica has worked with a range of clients across different industries in both Australia and Japan, with a focus on the consumer products and retail, technology and life sciences sectors. - Current at 31 October 2019


This was presented at VIC 7th Annual Tax Forum .

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Individual sessions

Legal professional privilege

Author(s):  Amber Agustin,  Fiona Knight

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ATO and large corporates

Author(s):  Chris Ferguson

Materials from this session:

ATO – Current issues for private groups

Author(s):  Anna Longley

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Division 7A – A new frontier

Author(s):  Michael PARKER

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