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Alternative Assets Insights: Imported hybrid mismatches

Published on 01 Jun 21 by "TAXATION IN AUSTRALIA" JOURNAL ARTICLE

Taxpayers need to consider PCG 2021/D3 in order to deduct payments made to offshore related parties.

Author profiles

Sach Pelpola
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Peter Collins FTI
Peter Collins, FTI, is a Partner at PwC with 25 years experience as a specialist in global tax, assisting foreign investors structuring their Australian investments and Australian corporates expanding offshore. He works with the firm’s global tax network to develop solutions for clients and is a member of the International Tax executive, which allows him to provide a unique global perspective. He is a consultant to Treasury in relation to tax reform in the areas of international tax and transfer pricing, including the MAAL/DPT and a member of the Treasury’s BEPS Tax Advisory Group. Peter was heavily involved in the rewrite of the Australian transfer pricing rules; he appeared before the Senate Estimates Committee to object to the retrospective application of those rules to US companies. He represented PwC before the Senate inquiry in relation to corporate tax avoidance by multinational companies. - Current at 01 November 2018
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