shopping_cart

Your shopping cart is empty

Arm’s length debt amount presentation

Member Price: Free
Non Member Price: Free
file_download Download

DisclaimerThis material is copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
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 18 Oct 21 by NATIONAL DIVISION, THE TAX INSTITUTE

This presentation covers:

  • What is the ALDA, and how is it used?
  • What are the practical issues and common pitfalls in applying the ALDA?
  • What is the ATO’s compliance approach to the arm’s length debt test outlined in PCG 2020/7?
  • What is the interaction with the transfer pricing regime?
  • Practical advice on managing the ATO’s risk assessment framework.

Author profiles

David Bell
David started his career at the Royal Military College Duntroon in 1979. From 1983 to 1988 he was a Commissioned Officer in the Infantry and resigned in the rank of Captain. Between 1988 and 1992 David was Chief of Staff to the NSW Minister for Agriculture and Deputy National Party Leader. In 1992, David entered the corporate world as a senior consultant at Andersen Consulting. He held positions as Managing Director at Gavin Anderson & Kortlang; Group Manager Corporate Affairs at Telstra; and General Manager Corporate Affairs & Communications at NRMA Insurance Limited. In January 2001, David was appointed Chief Executive Officer of the Australian Bankers' Association. - Current at 19 December 2004
Shahzeb Panhwar ATI
Shahzeb Panhwar is a Partner in PwC’s Tax Controversy practice. Shahzeb has extensive experience in international tax, tax structuring and transfer pricing matters across a number of industries. Before joining PwC Shahzeb was an Assistant Commissioner with the ATO and had strategic oversight of a number of strategic tax risks and strategies. - Current at 29 July 2022
Click here to expand/collapse more articles by Shahzeb Panhwar.

 

This was presented at The Tax Summit .

Get a 20% discount when you buy all the items from this event.

Individual sessions

Unique COVID-19 Employment Tax issues

Author(s):  Hayley Lock,  Stacey Biggar

Materials from this session:

International transactions

Author(s):  Mathew CHAMBERLAIN,  Madeleine Ottaviano,  Adele Williams

Materials from this session:

Tax write offs versus accounting write offs in an instant asset write off world

Author(s):  Stuart Glasgow

Materials from this session:

Employee versus Contractor – when is it still important?

Author(s):  Matthew McKEE

Materials from this session:

How to structure professional practices

Author(s):  Corey BEAT

Materials from this session:

Justice Graham Hill Memorial Lecture 2021 - The Process of Tax Reform: The Why, The When and The What

Author(s):  Julianne JAQUES

Materials from this session:

Tax management of worker costs

Author(s):  George Bendall

Materials from this session:

Residency – Individuals – Part 2

Author(s):  Leanne Connor,  Neil Brydges

Materials from this session:

Mr Spock’s Guide to Division 7A – XC ZB CA ZD RB

Author(s):  Ron JORGENSEN

Materials from this session:

Risky Business – advisers acting on behalf of clients and their entities

Author(s):  Loreena Gillon

Materials from this session:

Multiple party investment trust structures – Part 1: Federal taxes

Author(s):  Daniel SMEDLEY,  Laura Spencer

Materials from this session:

Multiple party investment trust structures – Part 3: State Taxes

Author(s):  Steven PATERSON

Materials from this session:

How much should I pay myself for what I do?

Author(s):  Paul SOKOLOWSKI,  Yina Tang

Materials from this session:

SMSFs – the current state of play

Author(s):  Liz Westover

Materials from this session:

Consolidation for smaller clients

Author(s):  Michael CHARLES,  Lucy Goldwater

Materials from this session:

Retaining and rewarding employees post pandemic

Author(s):  Cameron BLACKWOOD,  Toby EGGLESTON

Materials from this session:

Pitfalls of private practice

Author(s):  Alistair Little

Materials from this session:

40 years of Part IVA – a mid-term scorecard

Author(s):  Eugene Wheelahan

Materials from this session:

Reconstruction or recharacterisation under transfer pricing – arguments for and against

Author(s):  David BOND,  Fiona DILLON,  Dioni Perera

Materials from this session:

Current issues in consolidation

Author(s):  Ellen Thomas,  Adam Vassilieff,  Joseph Sahyoun

Materials from this session:

BEPS Pillars 1 and 2 – the latest developments in international tax reform

Author(s):  David BRADBURY

Materials from this session:

The rise of tax governance in the world of ATO Justified Trust engagements

Author(s):  Chris Vanderkley,  Glenn Cooper

Materials from this session:

ATO and FIRB – are they one and the same?

Author(s):  Keir CORNISH,  Michael Parris

Materials from this session:

Arm’s length debt amount

Author(s):  David BELL,  Shahzeb Panhwar

Materials from this session:

Legal Professional Privilege – The Accountant’s concession – recent cases and ATO activity

Author(s):  Mia Clarebrough,  Louisa Andolfatto

Materials from this session:

The Division 328 threshold tests - more than small business gateways

Author(s):  Anna WILSON,  Andrew Brown

Materials from this session:

Promoter penalties

Author(s):  Arthur ATHANASIOU

Materials from this session:

Common issues and pitfalls in tax loss preservation and loss carry back

Author(s):  David W MARKS

Materials from this session:

Tax aspects of insolvency in the current settings

Author(s):  Cameron Shaw,  Aaron Dominish,  Matthew Vines

Materials from this session:

CGT Rollover review

Author(s):  Matt Ervin,  Stacey Hannam

Materials from this session:

Multiple party investment trust structures – Part 2: Superannuation (SMSF) issues

Author(s):  Philippa Briglia,  Philip BRODERICK

Materials from this session:

Contemporary cross-border issues with trusts and estates

Author(s):  Sally BRUCE

Materials from this session:

Family Trust Elections and the Family Court

Author(s):  Danielle Constantine,  Todd Want

Materials from this session:

Trusts and unpaid present entitlements (UPEs)

Author(s):  Paul HOCKRIDGE

Materials from this session:

CGT implications of the surrender of life interests

Author(s):  Peter BOBBIN

Materials from this session:

SMSFs – NALI and NALE in the “real world”

Author(s):  John Ioannou,  Andrew Butler

Materials from this session:

The new online world of our clients

Author(s):  Adrian CARTLAND

Materials from this session:

Cryptocurrencies and NFT tax treatment – current state of play

Author(s):  Will Fennell,  Joni PIROVICH

Materials from this session:

Cases update

Author(s):  Adam Craig

Materials from this session:

Charity registration – what’s the purpose?

Author(s):  Anna Longley

Materials from this session:

Are you dealing with a valid trust?

Author(s):  Linda Tapiolas

Materials from this session:

Capital versus revenue – expansion of the basic principles

Author(s):  Kathryn Bertram,  Julian Wan

Materials from this session:

Building trust with the ATO

Author(s):  Renae Ali,  Justin BYRNE,  Annemarie Wilmore

Materials from this session:

Tax treaties – benefits conferred? benefits denied?

Author(s):  David WATKINS

Materials from this session:

Transfer Pricing – where to from here?

Author(s):  Kristen DEARDS,  Lorena Sosa

Materials from this session:

Current issues and considerations with corporate tax residency

Author(s):  Elizabeth Cullinan,  Vicky Lin

Materials from this session:

Intangibles and royalties – where are we heading?

Author(s):  Chris Ferguson

Materials from this session:

Tax Policy & Advocacy update: A debate by our experts

Author(s):  Scott TREATT,  Andrew MILLS,  Robyn Jacobson,  Julie Abdalla

Materials from this session:

Technology and taxation

Author(s):  Jimmy Nguyen

Materials from this session:

Structuring contractor arrangements

Author(s):  Adrian VARRASSO,  Wendy Lim,  Sasha Watkins

Materials from this session:

Tax Practitioner Board activity

Author(s):  Payne Karen,  Keith JAMES

Materials from this session:

ATO focus areas for the large market over the coming year

Author(s):  Rebecca SAINT

Materials from this session:

Shifting landscape of the distinction between capital and revenue

Author(s):  Angela Lee,  Terry MURPHY

Materials from this session:

Cost base issues

Author(s):  Louise Hickman

Materials from this session:

US and UK tax update session for Australian corporates

Author(s):  Stuart Landsberg,  Rob Hines

Materials from this session:

Developments in M&A

Author(s):  Darren McClafferty,  Sylvester Urban

Materials from this session:

Further details about this event:

 

Copyright Statement