Miscellaneous 2006

Tying the functional analysis in to common transacations and acceptable methodologies seminar

Source: New South Wales

Published Date: 19 Jul 2006

 

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Topics covered in this seminar paper include:
 
Classifying the related parties based on function, assets and risks "giving each party a functional description" for benchmarking purposes
 
Tying the classification into how related party pricing is set - for example the use of global price lists.
 
What are the appropriate methoidologies for setting the prices and testing the outcome for:
(i) a local distributor of imported trading stock
(ii) a local manufacturer and exporter of trading stock
(iii) a service providor both inwards and outwards
 
What is the difference between a service and a royality and what methodologies are generally recognized for setting and/or testing the arm's length nature of royalities?

If a foreign compant has a permanent establishment or a dependent agent in Australia, what is the methodology adopted by the PE/agent in dealing with its head office and other off shore related parties?

Individual Session

Tying the functional analysis in to common transactions and acceptable methodologies

Author(s): Doug Fone

Details

  • Published By: Doug Fone
  • Published On:19 Jul 2006
  • Took place at:Tattersalls Club, Sydney

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Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

This material is copyright. Apart from any fair dealing for the purpose of private study., research, critisism or review, as permitted under teh copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.

Unless expressly stated, opininons are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

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Miscellaneous 2006

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