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

Published on 01 Dec 15 by "TAXATION IN AUSTRALIA" JOURNAL ARTICLE

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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