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Transfer pricing implications of related party funding arrangements presentation
Published on 01 Nov 07 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE
This presentation covers:
- why this issue is important
- the evolution of ATO thinking
- the implications for planning and pricing of intercompany funding arrangements
- whether further guidance can be expected.
Author profile
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
This was presented at Annual Corporate Tax Intensive: Complex Tax Issues Uncorked .
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Thin capitalisation and AIFRS
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Transfer pricing implications of related party funding arrangements
Author(s): Paul BALKUSMaterials from this session:
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Recent corporate tax loss developments
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Current issues facing corporates in interpreting the debt equity rules in a cross border context
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Recent High Court decisions on the capital-income divide
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Carbon consequences: preparing for the Australian emissions trading system: flow-on tax consequences
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Corporate acquisitions and demergers
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Failing to withhold non-resident withholding tax
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