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Transfer pricing v the diverted profits tax – Too much overlap to be safe! paper

Published on 11 Oct 18 by VICTORIAN DIVISION, THE TAX INSTITUTE

This paper covers:

  • purpose of the DPT
  • overview of the DPT
  • the relevant taxpayer must obtain a DPT tax benefit in connection with the scheme
  • the principal purpose test – paragraph 177J(1)(b)
  • the sufficient economic substance test – s177M
  • PCG 2018/5 – DPT risk assessment framework and SES test scenarios.

Author profile

Damian Preshaw CTA
Damian Preshaw is a transfer pricing specialist with more than 25 years’ experience in both the private sector and with the Australian Taxation Office and provides specialist transfer pricing services to accounting firms and law firms. Prior to establishing Damian Preshaw Consulting Pty Ltd, Damian was a director in KPMG’s Transfer Pricing Services Group in Melbourne for 12 years. In this capacity, Damian advised a wide variety of multinational clients on transfer pricing and profit attribution issues with a special focus on dispute resolution, financial services, financial transactions and business restructuring. Before joining KPMG, Damian was an international tax counsel in the ATO’s Transfer Pricing Practice in Canberra where he was extensively involved in the ATO’s transfer pricing rulings program and was an Australian delegate to the OECD’s Working Party No.6 (Taxation of Multinational Enterprises) from 1994 to 2003. Damian is a Chartered Tax Adviser and represented The Tax Institute on the ATO’s Division 815 Technical Working Group. Damian has twice appeared as a witness before the Senate Economics Legislative Committee’s hearings in relation to Australia’s new transfer pricing rules on behalf of The Tax Institute. - Current at 09 July 2020
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This was presented at VIC 6th Annual Tax Forum .

Get a 20% discount when you buy all the items from this event.

Individual sessions

Tax issues with cryptocurrencies

Author(s):  Gareth Redenbach

Materials from this session:




Transfer pricing v the diverted profits tax – Too much overlap to be safe!

Author(s):  Damian PRESHAW

Materials from this session:

Legislative reforms in the property sector

Author(s):  Robyn Jacobson,  James Christodoulakis

Materials from this session:

RCF IV: Limited partnerships, unlimited implications?

Author(s):  Gareth Redenbach,  James STRONG

Materials from this session:

Private business: What’s attracting the Commissioner’s attention?

Author(s):  Anna Longley

Materials from this session:

Further details about this event:

 

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