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Alternative assets insights: TA 2020/1: Intangible assets


The ATO continues its focus on cross-border arrangements involving intangible assets with the release of TA 2020/1.

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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Jonathan Malone CTA
Jonathan is a Partner in PwC’s Global Tax Practice with over 18 years experience as a corporate tax adviser, specialising in international tax, M&A, cross-border related party arrangements and tax policy considerations. Jonathan advises global technology companies on their operations in Australia, along with the tax implications arising from cross-border transactions. - Current at 26 June 2019
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