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Alternative assets insights: Stapled groups and the new arm’s length income rule


This article discusses the application of transfer pricing principles to cross-staple leasing structures under the non-arm’s length income rule in the proposed new tax regime for managed investment trusts.

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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Benjamin Lannan ATI
Ben is a Partner in PwC's Transfer Pricing practice, based in Brisbane and a member of PwC's Global Transfer Pricing network. Ben has over 16 years experience in transfer pricing, assisting a range of clients to develop and implement defendable transfer pricing strategies. Ben regularly speaks on transfer pricing at events. Ben has a Bachelor of Economics from Monash University and is a member of the Institute of Chartered Accountants. - Current at 30 April 2015
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Dritton Jemaylay
Dritton is Director – Transfer pricing PricewaterhouseCoopers.
Current at 1 December 2015


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