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A new phase in transfer pricing dispute resolution in Australia video


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Member Price: $99.00
Non Member Price: $121.00

Publication date: 09 Sep 21 | Source: NATIONAL DIVISION, THE TAX INSTITUTE

Abstract:
This video covers:

  • The role that your evidence can play in a domestic court strategy relative to a MAP strategy in light of Glencore
  • The impact of a multinational group’s domestic dispute resolution strategy (i.e., to settle or to litigate) on potentially achieving a resolution via MAP/arbitration
  • For both the multinational taxpayer and the ATO, the tension between preserving rights under domestic tax laws and achieving resolution via MAP / arbitration
  • The impact of mandatory binding arbitration on the prospects of achieving resolution via MAP; and
  • The OECD’s desire to change the dialogue from ‘dispute resolution’ to ‘dispute prevention’ and what this might mean for multinational groups’ dispute resolution strategies in the future.

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A new phase in transfer pricing dispute resolution in Australia
Author(s):  Martin FRY,  Thomas Ickeringill

Author profiles

Martin Fry FTI
Martin Fry, FTI, is the Practice Leader of the Allens Tax Group. With over 20 years as a Partner of Allens, Martin advises corporations on a broad range of tax issues across a wide range of sectors, including resources, infrastructure, financial services and IP-intensive businesses. In recent years, Martin has focused on contentious transfer pricing matters, including audits, settlement negotiations, mutual agreement procedure and litigation. Martin has taught Corporate Tax at a postgraduate level at the University of Melbourne. - Current at 12 May 2021
Click here to expand/collapse more articles by Martin FRY.
Thomas Ickeringill
This was presented at 2021 National Transfer Pricing Conference .

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