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Branch attribution for banks presentation

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Published on 06 Feb 19 by NATIONAL DIVISION, THE TAX INSTITUTE

This presentation covers:

  • banking landscape
  • typical structures
  • legal framework
  • current areas of focus for the ATO
  • insight from the tax avoidance taskforce (top 100 and top 1000 programs)
  • RBA vs FSE in practice – is there much difference?
  • what does this mean for taxpayers seeking assurance over branch attribution outcomes?
  • scope for Australia adopting the FSE under the Authorised OECD approach.

Author profiles

Julian Pinson
Julian Pinson, FTI is a Partner at PwC. Julian advises on a wide range of tax matters, with a focus on banking and financial services and M&A. Julian has particular expertise in cross-border finance, TOFA, corporate restructures, debt and equity raisings and M&A. - Current at 02 November 2023
Click here to expand/collapse more articles by Julian PINSON.
James Campbell
James Campbell is a Director, leading the Banking and Finance Strategy and work program for income tax in the Public Groups business line of the ATO. James has over 20 years experience in compliance, audit, public advice and policy development with a focus on the banking and finance industry. Areas of expertise include capital management and hybrid financing, transfer pricing, branch attribution, CFC rules Part IIIB, thin capitalisation and M&A. - Current at 20 November 2025

 

This was presented at 2019 Financial Services Taxation Conference .

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