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Intangibles in the spotlight – Cross border tax issues podcast
Published on 27 May 21 by QUEENSLAND DIVISION, THE TAX INSTITUTE
This podcast covers practical insights into the requirements of Chapter VI of the OECD TP Guidelines when dealing with Intangibles and the Australian Taxation Office’s guidance when transacting on a cross-border basis with related parties.
Author profiles
Tim Heberden
Tim Heberden is a Partner at Deloitte where he leads the IP Advisory team that specialises in quantifying and optimising the value of intangible assets. He has valued IP assets for purposes as diverse as transfer pricing, litigation, M&A and strategy determination. Tim is listed in the IAM Strategy 300 – the World’s Leading IP Strategists. He is the technical author of the Guidance Note on the Valuation of Intellectual Property Rights, and is author of a chapter on royalty determination for ‘International Licensing and Technology Transfer: Practice and the Law’. He is a CA ANZ; MBA; Registered Business Valuer; Fellow of the Australian Marketing Institute, and Fellow of the Royal Institution of Chartered Surveyors. - Current at 08 July 2020Jacques Van Rhyn ATI
Jacques is an international tax and transfer pricing partner focused on the oil and gas sector and is the leader of the Brisbane Tax practice for Deloitte. He has been in professional practice for 27 years, including 17 years in international tax and transfer pricing practices within Big Four firms, and 10 years practising as a commercial attorney in an in-house capacity and for his own account. Jacques has extensive experience advising multinational companies on various cross-border tax and transfer pricing issues, especially in the energy and resources sector, with a specific focus on mining, oil and gas and related services companies. He has also been listed in Euromoney’s Expert Guide to the World’s Leading Transfer Pricing Advisers in South Africa and Australia as well as the World’s Leading Controversy Lawyers. In addition, he has published articles on international tax and transfer pricing, mining and oil and gas, and contributed to several intellectual property publications. - Current at 13 August 2018Chris Ferguson
Chris Ferguson is a Partner in Deloitte Legal Australia who has considerable experience in the fields of international tax, taxation of intangible arrangements, tax administration and tax controversy. Chris’ specialist advice is informed by his time advising clients at Deloitte coupled with his varied experience whilst performing Assistant Commissioner roles at the Australian Taxation Office. Chris’ experience allows him to expertly advise clients in respect of key considerations for companies implementing business restructures, current issues and risk associated with the taxation of intangible arrangements, administrator expectations regarding tax compliance and governance procedures and ATO engagement, tax controversy and complex dispute resolution strategies. - Current at 03 June 2025
This was presented at 2021 Queensland Tax Forum .
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Individual sessions
Intangibles in the spotlight - Cross border tax issues
Author(s): Tim Heberden, Jacques Van RhynMaterials from this session:
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Trusts – 100A reimbursement agreements; identifying and reducing taxpayer risks
Author(s): Mark WESTMaterials from this session:
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Hybrids – Lessons learnt and responses
Author(s): Michael CHANGMaterials from this session:
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Transparency when dealing with the ATO
Author(s): Fletch HEINEMANN, Sarah LancasterMaterials from this session:
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Topical issues affecting cross-border capital management
Author(s): Kevin GRIFFITHS, Catherine ParkinsonMaterials from this session:
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GST assurance reviews
Author(s): Nicole Brown, Anika Reside, Tony WINDLEMaterials from this session:
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Reflections on COVID relief measures
Author(s): Alison Feather, Katrina PivaMaterials from this session:
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Recruiting and retaining top talent
Author(s): Aaron Dahl, Melinda PetersMaterials from this session:
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Managing uncertainty in a transparent environment
Author(s): Andrew JonesMaterials from this session:
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Corporate M&A in a post-pandemic world
Author(s): Nicholas Allen-Waters, Evan LastMaterials from this session:
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What happens where the intended use of property changes?
Author(s): Sian SinclairMaterials from this session:
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Cases update – staying informed
Author(s): Emily Falcke, Chris Stewart, Lauren Markopoulos, Anthony MartinMaterials from this session:
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Outbound investment issues
Author(s): Paul MillsMaterials from this session:
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