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Transfer pricing update paper

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Published on 17 Oct 19 by VICTORIAN DIVISION, THE TAX INSTITUTE

This paper covers:

  • compliance issues and the use of PCGs
  • justified trust initiatives
  • APA program status
  • other recent developments.

Author profiles

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
Click here to expand/collapse more articles by Michael JENKINS.
Jessica Uchida
Jessica Uchida joined EY in March 2009 and is a senior manager in the transfer pricing practice. She recently returned to Melbourne, having completed a four-year secondment with EY Japan’s Tokyo practice. Jessica has almost 10 years professional transfer pricing experience, supporting clients with transfer pricing and BEPS compliance, planning advice and controversy support. Jessica has worked with a range of clients across different industries in both Australia and Japan, with a focus on the consumer products and retail, technology and life sciences sectors. - Current at 31 October 2019

 

This was presented at VIC 7th Annual Tax Forum .

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SME cases update

Author(s):  Robyn Jacobson

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Corporate cases update

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Professional firms - A history of the technical landscape

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M&A: Is it safe to go back in the water?

Author(s):  Enzo COIA,  Anna Williams

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SME M&A update

Author(s):  Daniel Burt,  Stuart Dall

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Legal professional privilege

Author(s):  Amber Agustin,  Fiona Knight

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ATO and large corporates

Author(s):  Chris Ferguson

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ATO – Current issues for private groups

Author(s):  Anna Longley

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Unintended consequences: Think twice about family law

Author(s):  Tracey Dunn,  Helen Suke

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Foreign resident capital gains withholding – 3 years on – Where are we now?

Author(s):  David Earl,  Lynn KOH,  Tim Lewis,  Jake Selleck

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Australian residents, foreign trusts and foreign funds – The new black!

Author(s):  Neil Brydges

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Division 7A – A new frontier

Author(s):  Michael PARKER

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State taxes update

Author(s):  Nicholas Clifton

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Individual tax residency

Author(s):  Julianne JAQUES

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Director’s liability

Author(s):  Tamara CARDAN,  James Donoghue

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Super death benefits and conflicts of interest – The latest battleground

Author(s):  Philip BRODERICK

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Corporate tax residency: State of play

Author(s):  Denise HONEY

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Research and development tax incentive (RDTI) update

Author(s):  Chris Vittas

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How taxpayers can discharge their burden of proof

Author(s):  Gareth Redenbach

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Estate planning: Not an exercise just for the rich and famous

Author(s):  Nathan Yii

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Transfer pricing update

Author(s):  Michael JENKINS,  Jessica Uchida

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