Anti-avoidance Transfer pricing

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

Details

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

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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Anti-avoidance Transfer pricing 2018

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