Thin capitalisation including the impact of falling asset values paper

Paul Balkus

Paul is the co-leader of Ernst & Young’s Oceania Transfer Pricing practice. He has over 20 years experience in the field of tax and transfer pricing including significant experience in servicing clients across most industries including financial services, mining and resources, pharmaceutical and fast moving consumer goods. Paul has been involved in all aspects of transfer pricing including advance pricing arrangements, dispute resolution, planning and documentation. More specifically, Paul’s experience has included addressing transfer pricing issues in connection with inter-company arrangements involving supply chain restructuring arrangements, global funds management, credit and performance guarantees, global trading and intercompany financing. - Current at 14 July 2017

Daryl Choo ATI

Daryl leads EY’s transaction tax practice within the financial services group. She is a tax partner with over 25 years of tax experience with EY. Daryl has extensive Australian and international tax experience including a 5 year secondment to EY London. Her clients primarily operate in the wealth and asset management and banking and finance sectors. Daryl specialises in providing tax advice on the structuring of international and domestic funds/products; tax due diligence on the acquisition of international and domestic entities; IPO of international and domestic entities; and pre and post transaction restructures. - Current at 12 January 2022