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National Transfer Pricing Conference

Published on 08 Aug 2018 | Took place at Four Seasons Hotel Sydney, Sydney, NSW

Transfer pricing continues to be a topical issue for taxpayers and revenue authorities in Australia and around the world. The OECD’s base erosion and profit shifting (BEPS) project, and Australia’s implementation of many of its recommendations, highlight the importance of transfer pricing to the compliance and governance frameworks of affected taxpayers. The conference included addresses from thought leaders from both the profession and the Australian Taxation Office, covered were difficult technical issues on the migration of intellectual property and the application of Div 815 following Chevron and highlighted what transfer pricing risks boards must consider in discharging their directors’ duties.

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Individual sessions

Simplifying transfer pricing

Author(s):  Lauren Whelan

This paper covers:

  • proposed changes
  • questions specific to the simplified transfer pricing record keeping options.
Materials from this session:

Basics of transfer pricing documentation

Author(s):  Ashish DAVE

This paper covers:

  • regulatory framework
  • determining the appropriate intercompany price
  • developing support for actual pricing.
Materials from this session:

Taxing inbound and outbound capital: Future realised TIA TP conference Sydney

Author(s):  Danielle DONOVAN

This presentation covers:

  • what does the future look like?
  • taxing inbound capital
  • inbound debt walk through
  • taxing outbound capital wheel
  • outbound debt
  • guarantee fees
  • ATO engagement.
Materials from this session:

Correct characterisation and reconstruction under Subdivision 815-B and Part IVA

Author(s):  Damian PRESHAW

This paper covers:

  • the most frequent areas where international related party dealings are being challenged by the ATO in transfer pricing cases
  • how Subdivision 815-B and recent changes to the OECD’s transfer pricing guidelines address the characterisation and reconstruction of international related party dealings
  • in the planning phase and post implementation, what steps companies should be taking to document and support their tax governance.
Materials from this session:

IP migration – core tax rules, TP, and the interaction with DPT

Author(s):  Jonathan Malone,  Karim Raphaël

This presentation covers:

  • scenarios
  • core tax rules
  • TP
  • DPT and tax benefit
  • ATO compliance approach.

 

Materials from this session: