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Alternative assets insights: PCG 2019/D3: A way forward on the ALDT

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Published on 01 Oct 19 by "TAXATION IN AUSTRALIA" JOURNAL ARTICLE

The latest ATO guidance suggests that a detailed robust analysis, along with corresponding evidence, is key to satisfying the arm’s length debt test.

Author profiles

Edwin Baghdasarayan ATI
Edwin is a Transfer Pricing Partner within the PwC Australia Global Tax practice, based in Sydney. He has practiced transfer pricing at PwC since 2007 and has been involved in assisting numerous Australian, US and NZ top listed multinationals in their global transfer pricing across the entire lifecycle including consulting, structuring and planning, documentation, managing risk reviews, audits and unilateral/bilateral APAs. His experience ranges across a variety of industries, including financial services, consumer & industrial products, resources, logistics/transport and the technology sector. In particular, he has extensive experience in transfer pricing consulting for financial transactions, including funding across various industries and corporate purposes, financial instruments (e.g., options, swaps & forwards), cash pooling, guarantee fees and thin capitalisation/debt characterisation. As part of this experience, he has actively contributed to financial transactions transfer pricing thought leadership within both the US and the Asia Pacific region including drafting publications, leading presentations and various other policy initiatives. - Current at 22 October 2020
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Nick Houseman CTA
Nick Houseman FTIA is a Partner in Transfer Pricing at PricewaterhouseCoopers, Sydney. Nick has over 15 years experience advising on transfer pricing matters with a focus on the financial services sector. Nick also has extensive experience in local and global transfer pricing documentation and compliance, tax planning, negotiations of Advance Pricing Agreements, competent authority negotiations, litigation support and audit defence in the financial services industry and other industries for well known Australian and foreign companies. Nick has managed many significant regional and global projects based in Asia-Pacific and European regions and has conducted many in-depth financial and economic analyses throughout the financial services industry. - Current at 01 January 2014
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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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