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Transfer pricing & financing presentation


This presentation covers:

  • Australian and global transfer pricing landscape
  • ATO’s transfer pricing compliance activity
  • common outbound transactions
  • ATO’s simplified record keeping measures
  • managing your transfer pricing risk.

Author profiles

Zubin Sadri CTA
Zubin is an Account Director with Deloitte who specialises in advising on International Tax issues relating to inbound and outbound Australian investment. Zubin has extensive experience advising clients (particularly in the Energy & Resources industry) on M&A transactions and international structuring issues, including tax effective financing and profit repatriation, treatment of foreign source income, application of tax treaties, cross-border leasing and Australia's controlled foreign company rules. - Current at 03 October 2016
Janelle Sadri
Janelle is an Account Director in the Deloitte Perth transfer pricing practice. Janelle has over 7 years of experience in both corporate/international tax and transfer pricing. Janelle has advised on several significant inbound and outbound structuring projects in the natural resources sector, including finance structuring and debt pricing to support arm’s length gearing / interest levels, and business restructures involving the movement of key profit driving functions and the migration of intellectual property. Janelle has provided advice in relation to the interpretation and application of the arm’s length principle in an MRRT and PRRT context. Janelle has also project managed and successfully negotiated unilateral and bilateral Advance Pricing Arrangements (APAs), delivered regional/global transfer pricing planning and documentation studies, and has assisted clients in transfer pricing risk reviews and audit settlements. Janelle has published articles on transfer pricing issues in Asia Pacific journal
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This was presented at SME Outbound Tax Issues .

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Individual sessions

Transfer pricing & financing

Author(s):  Zubin SADRI,  Janelle Sadri

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