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Tax risk and financing transactions – An ATO perspective presentation
Published on 18 May 17 by NATIONAL DIVISION, THE TAX INSTITUTE
This presentation covers:
- landscape of cross-border flows
- focus areas:
- interest rate / currency
- transfer pricing and Chevron decision
- guarantee fees
- thin capitalisation integrity
- debt creation/ Loan backs
- synthesised arrangements
- public advice and guidance.
Author profile
Jeremy Hirschhorn CTA
Jeremy Hirschhorn was appointed to act in the role of Second Commissioner in December 2018. He has overall responsibility for the ATO’s Client Engagement Group, which fosters willing participation in Australia’s tax and super systems through well-designed client experiences. Jeremy has more than 20 years' experience in roles managing complex tax matters. As Deputy Commissioner of Public Groups & International from April 2015, Jeremy was responsible for ensuring that the largest Australian and multinational companies were meeting their corporate tax obligations, and providing the Australian community with confidence that these large companies were being held to account. Jeremy also worked as Chief Tax Counsel, with responsibility for the provision of the ATO’s legal advice in relation to interpretation of the tax and super laws, when he joined the ATO in August 2014. Prior to joining the ATO, Jeremy was a senior partner in KPMG’s tax practice. Jeremy holds a Bachelor of Commerce and Bachelor of Laws from the University of NSW. He is a Chartered Tax Adviser and Chartered Accountant. - Current at 19 November 2020
This was presented at NSW 10th Annual Tax Forum .
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