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Transfer pricing – ATO perspectives paper

Published on 21 May 15 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This paper covers:

  • the previous provisions
  • 815-A and 815-B
  • issues in administration.

Author profile

Michael Jenkins CTA
Michael Jenkins, CTA, is an EY transfer pricing partner based in Melbourne. He has worked in the field of transfer pricing since the 1990s. His transfer pricing expertise includes dispute resolution while in practice; and as the leader of the ATO’s APA/MAP unit and Australian competent authority. He was heavily involved in the development of Australia’s transfer pricing rules (Division 815) and was an Australian delegate to the OECD’s transfer pricing working party (WP6) 2010-2018. - Current at 04 June 2025
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This was presented at NSW 8th Annual Tax Forum .

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ADR in a tax context from a mediator’s perspective

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