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Legislative changes to the transfer pricing rules - The state of play presentation

Published on 18 Sep 13 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

Australian transfer pricing laws have undergone their most radical change in 30 years and it will impact every Australian multinational. This presentation provides an overview of the background and drivers for the legislative changes, and an overview of the key changes and implications for MNCs.

It covers:

  • background and drivers for change in the Australian transfer pricing legislation
  • relevance and interaction between Division 13, s815-A and the new s815-B and s815-C laws
  • key aspects of the new legislation, including application of the arm’s length principle, relevance of economic substance and ATO reconstruction powers, and requirements for transfer pricing documentation
  • implications for MNCs historical and future transfer pricing positions
  • treaty partner considerations and dispute resolution mechanisms.

Author profile

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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Legislative changes to the transfer pricing rules - The practical implications

Author(s):  Tony Gorgas

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