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2021 National Transfer Pricing Conference

Published on 09 Sep 2021 | Took place at Online, National

This event covered the following:

  • Hearing from the ATO in relation to the development and execution of the ATO’s transfer pricing strategy, the role of the Economist Practice and the draft PCG on intangibles
  • A panel discussion involving legal and accounting specialists involved in transfer pricing cases
  • Looking at the latest international developments in relation to the OECD/G20’s work on Pillar 1 and Pillar 2 and future trends in tax transparency and what it means for MNE groups
  • Rethinking past approaches in relation to transfer pricing dispute resolution and dealing with financial transactions
  • Practical insights from corporate Australia in dealing with the ATO’s justified trust program and the evolving nature of the in-house transfer pricing function
  • Technical sessions addressing characterisation issues in a transfer pricing context, the intersection of transfer pricing and Part IVA, customs duty and transfer pricing and the ever-expanding definition of a SGE.

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Individual sessions

BEPS 2.0: Update on Pillar 1

Author(s):  Michael JENKINS,  Nick Marshall

This paper covers issues associated with ‘Pillar 1’ of the BEPS 2.0 agenda and will revisit the fundamental components of Pillar 1 in light of the most recent developments arising from the July 2021 meeting of the G20 Finance Ministers.

Materials from this session:

How does transfer pricing affect customs duty and the amount of indirect taxes paid?

Author(s):  Lorena Sosa,  Richard Nutt

This paper covers:

  • The impacts of transfer pricing policies on customs duty and indirect taxes paid in the current environment, including practical examples of the impact of the changes in the global tariff landscape
  • The relevance of trying to align the TP pricing to the customs duty assessment;
  • Implications of the potential disconnect between the customs valuation method and the transfer pricing method applied, and in particular, the potential custom duty impacts when using a transfer pricing method that measures the arm’s length result on an aggregate basis (TNMM or APAs);
  • The importance of considering year-end TP adjustments and whether they are made within the parameters stated in the customs valuation 
  • Practical examples of transactions that should be considered/reviewed.

 

Materials from this session:

A new phase in transfer pricing dispute resolution in Australia

Author(s):  Martin FRY,  Thomas Ickeringill

This paper covers:

  • The role that your evidence can play in a domestic court strategy relative to a MAP strategy in light of Glencore
  • The impact of a multinational group’s domestic dispute resolution strategy (i.e., to settle or to litigate) on potentially achieving a resolution via MAP/arbitration
  • For both the multinational taxpayer and the ATO, the tension between preserving rights under domestic tax laws and achieving resolution via MAP / arbitration
  • The impact of mandatory binding arbitration on the prospects of achieving resolution via MAP; and
  • The OECD’s desire to change the dialogue from ‘dispute resolution’ to ‘dispute prevention’ and what this might mean for multinational groups’ dispute resolution strategies in the future.
Materials from this session:

A practical approach to financial transactions

Author(s):  Frank PUTRINO,  Sean Madden

This session will compare and contrast worked examples of small (less than $10m) and large (greater than $1b) related party loans (including derivatives and outbound interest-free loans) in the current Australian transfer pricing environment.

Materials from this session:

Future trends, increased transparency and what it means for MNC businesses

Author(s):  Tammy Eccles,  Tony Gorgas

This paper covers:

  • Recent trends in Europe leading towards mandatory public disclosure of tax information
  • Using some example case studies, how Australian outbound MNCs can be impacted by these rules even though the same rules don’t (yet) apply in Australia
  • Whether publishing more information solves (or exacerbates) the issue of trust; and
  • Where will it end?
Materials from this session:

The ATO’s intangibles strategy and draft PCG on intangibles

Author(s):  Chris Ferguson

This presentation covers:

  • The ATO’s intangibles strategy
  • Draft PCG on intangibles
  • Practical application.
Materials from this session:

OECD’s Pillar 2 global minimum tax proposal: Taking the pressure off transfer pricing

Author(s):  Richard J VANN,  Mary Hu

This paper covers:

  • The current state of play on the OECD’s Pillar 2 program
  • An overview of the Pillar 2 domestic law change proposals (the income inclusion rule and the undertaxed payments rule, together known as the GloBE rules) including identifying which entities are in-scope, the effective tax rate (ETR) calculation and identifying who pays the top-up tax
  • An overview of the Pillar 2 treaty based changes (the switch-over rule and subject to tax rule)
  • An analysis of implementation issues and next steps
  • Consideration of the major impacts of the changes, especially on transfer pricing.
Materials from this session:

Provision of services or rights to use intangibles

Author(s):  David BOND

This presentation covers the distinction between the provision of services and the granting of rights to use intangibles in interactions between members of MNE groups.

Materials from this session:

Transfer Pricing and the Application of Part IVA

Author(s):  Toby KNIGHT,  Anfeng He

This paper covers questions that might arise from the intersection of transfer pricing and Part IVA.

Materials from this session:

Expanded definition of SGE

Author(s):  Michael SMITH,  Natalya Marenina

This paper covers:

  • Discuss why it’s critical for every taxpayer to know whether they are a SGE
  • Examine the revised definition of SGE and how it may impact your business
  • Introduce the concept of Country-by-Country reporting entity (CBCrE)
  • Work through SGE and CBCrE case studies; and
  • Look in detail at what it means to be an SGE and CBCrE and how that is likely to change a taxpayer’s compliance cycle.
Materials from this session: