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  Anti-avoidance Transfer pricing

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

Source: New South Wales

Published Date: 8 Aug 2018

 

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This paper covers:

  • the most frequent areas where international related party dealings are being challenged by the ATO in transfer pricing cases
  • how Subdivision 815-B and recent changes to the OECD's transfer pricing guidelines address the characterisation and reconstruction of international related party dealings
  • in the planning phase and post implementation, what steps companies should be taking to document and support their tax governance.
Author(s)

Individual Session

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

Author(s): Damian Preshaw
Materials from this session:

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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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