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Transfer pricing v the diverted profits tax – Too much overlap to be safe! paper

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Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

Published on 11 Oct 18 by VICTORIAN DIVISION, THE TAX INSTITUTE

This paper covers:

  • purpose of the DPT
  • overview of the DPT
  • the relevant taxpayer must obtain a DPT tax benefit in connection with the scheme
  • the principal purpose test – paragraph 177J(1)(b)
  • the sufficient economic substance test – s177M
  • PCG 2018/5 – DPT risk assessment framework and SES test scenarios.

Author profile

Damian Preshaw CTA
Damian Preshaw, CTA, is a transfer pricing specialist with more than 30 years’ experience in both the private sector and with the Australian Taxation Office and provides specialist transfer pricing services to accounting firms and law firms. Prior to establishing Damian Preshaw Consulting Pty Ltd, Damian was a director in KPMG’s Transfer Pricing Services Group in Melbourne for 12 years. In this capacity, Damian advised a wide variety of multinational clients on transfer pricing and profit attribution issues with a special focus on dispute resolution, financial services, financial transactions and business restructuring. Before joining KPMG, Damian was an international tax counsel in the ATO’s Transfer Pricing Practice in Canberra where he was extensively involved in the ATO’s transfer pricing rulings program and was an Australian delegate to the OECD’s Working Party No.6 (Taxation of Multinational Enterprises) from 1994 to 2003. - Current at 14 July 2023
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This was presented at VIC 6th Annual Tax Forum .

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