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Transfer pricing and related party debt presentation


This presentation covers:

  • Chevron
  • ATO Draft PCG 2017/D4
  • practical examples of approaching debt pricing
  • other related issues.

Author profiles

James Nickless
James Nickless is a tax partner specialising in transfer pricing and international tax at PwC. James has significant experience advising on cross-border funding structures from a transfer pricing and international tax perspective. James has advised a variety of infrastructure investors in relation to their capital structures as well as cross-staple lease pricing.James has been involved with the ATO and Treasury consultation process in relation to guidance on related party debt arrangements, the diverted profits tax and anti-hybrid rules. James is a Member of Chartered Accountants Australia & New Zealand. - Current at 05 May 2018
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Caleb Khoo
Caleb is a Legal Partner in the PwC Australia, Tax Controversy Group. Caleb has significant experience in complex tax audits and disputes with the Australian Taxation Office. This includes litigation before the High Court of Australia, Federal Court of Australia and the Administrative Appeals Tribunal. It also includes the use of alternative dispute resolution mechanisms and settlement negotiations to resolve large and complex audits and disputes prior to and in the course of litigation proceedings. Caleb has represented large corporations across a number of industries including mining, infrastructure and construction, telecommunications and consumer goods. He has provided legal advice and services concerning the application of income tax laws, transfer pricing rules, general anti-avoidance rules, tax treaties and administrative law. He has briefed and continues to work with global industry leading experts in banking and finance in preparation for debt pricing disputes. - Current at 23 November 2017
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This was presented at Corporate Tax Masterclass .

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