Miscellaneous 2009

Profit attribution to permanent establishments and transfer pricing following the Roche case

Source: National

Published Date: 12 Feb 2009

 

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The OECD finally released its Report on Attribution of Profits to PEs in July. This paper covers:

  • so what is the ‘Authorised OECD Approach'?
  • how will it fit with the ATO's guidance on attribution of profits to PEs in Australia?
  • what are the important issues for Australian taxpayers to be aware of?

The Roche Case was Australia's first legal decision on a substantive transfer pricing matter since the introduction of Division 13:

  • what does the decision mean for taxpayers and the ATO?
  • are profit methods dead?
  • what does it mean for the financial services sector?

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Profit attribution to permanent establishments and transfer pricing following the Roche case

Author(s): Nick Houseman

Details

  • Published By: Nick Houseman
  • Published On:12 Feb 2009
  • Took place at:Surfers Paradise Marriott Resort & Spa

The material is copyright. Apart any fair dealing for the purpose of private study,

research critisism or review, as permitted under the copyright Act, no part may be rerpoduced by any process without written permission from The Tax Institute.

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 2009

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