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The transfer pricing “reconstruction” provisions: Recharacterising, repricing or reimagining paper

Published on 27 Aug 15 by QUEENSLAND DIVISION, THE TAX INSTITUTE

This paper covers:

  • overview of Subdivision 815-B
  • reconstruction under Subdivision 815-B
  • recent experiences and options for obtaining certainty
  • emerging transfer pricing compliance trends.

Author profiles

Benjamin Lannan
Ben is a Partner in PwC's Transfer Pricing practice, based in Brisbane and a member of PwC's Global Transfer Pricing network. Ben has over 16 years experience in transfer pricing, assisting a range of clients to develop and implement defendable transfer pricing strategies. Ben regularly speaks on transfer pricing at events. Ben has a Bachelor of Economics from Monash University and is a member of the Institute of Chartered Accountants. - Current at 30 April 2015
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Dritton Jemmalay
Dritton Jemmalay is the Managing Partner of TP benchmark, a specialised full service transfer pricing advisory house founded in 2021, serving multinationals, accounting and law firms across Australia and abroad. Dritton has specialised in transfer pricing for over 16 years, which has included over a decade advising for the Big 4 and a number of years as in-house counsel across a number of Australian listed companies. - Current at 21 January 2025
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This was presented at 2015 Queensland Tax Forum .

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Individual sessions






Transfer pricing documentation: Country by country reporting

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Proposed new managed investment trust regime

Author(s):  Pratish Patel

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