Anti-avoidance Transfer pricing International tax & business

Correct characterisation and reconstruction under 815B and Part IVA

Source: New South Wales

Published Date: 8 Aug 2018


This presentation covers:

  • the basic rule " ss815-130(1)
  • the first exception " ss815-130(2)
  • what is the meaning of the words form' and substance'?
  • substance over form in the United States
  • what is an inconsistency between form' and substance'?
  • what is the effect of disregarding some or all of the form' of the commercial or financial relations?
  • relevance of OECD TP Guidelines " s815-135
  • steps companies should be taking to document and support their tax governance.

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Individual Session

Correct characterisation and reconstruction under Subdivision 815-B and Part IVA

Author(s): Damian Preshaw CTA


  • Published By: Damian Preshaw CTA
  • Published On:8 Aug 2018
  • Took place at:Four Seasons Hotel Sydney, Sydney

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Anti-avoidance Transfer pricing International tax & business 2018

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