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Transfer pricing – How much does your debt cost paper?

Published on 18 Nov 08 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This paper:

  • outlines the transfer pricing impacts of the global credit crunch
  • discusses how to determine arm's length interest rates and take account of key factors such as borrower credit worthiness and characteristics of the loan
  • discusses the practical impact of the ATO's recent publications on the issue of debt finance, and the major areas of controversy
  • provides practical guidance on how to deal with the thorny issue of how to price loan guarantees.

Author profiles

Geoffrey Gill ATI
Photo of author, Geoff GILL Geoff Gill is a transfer pricing partner with Deloitte based in Sydney with close to 25 years of experience in transfer pricing practice. Geoff specialises in transfer pricing for the Financial Services and Technology, Media and Telecoms sectors, as well as transfer pricing issues relating to financial transactions. He is an economist with a degree in economics from Trinity College Dublin and a masters in economics from University of Oxford. - Current at 09 August 2023
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David Grecian
David Grecian is currently National Director with Deloitte Touche Tohmatsu in Melbourne. David has nearly 30 years’ experience in transfer pricing case work, litigation, public rulings and policy. As Chair of the OECD WP6 and the Steering Group on transfer pricing in Paris, he was the senior official responsible for the development of the OECD report on attribution of profits to permanent establishments, including banking, global trading and insurance. - Current at 03 September 2010
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