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Correct characterisation and reconstruction under 815B and Part IVA presentation

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Published on 08 Aug 18 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This presentation covers:

  • the basic rule – ss815-130(1)
  • the first exception – ss815-130(2)
  • what is the meaning of the words ‘form’ and ‘substance’?
  • substance over form in the United States
  • what is an inconsistency between ‘form’ and ‘substance’?
  • what is the effect of disregarding some or all of the ‘form’ of the commercial or financial relations?
  • relevance of OECD TP Guidelines – s815-135
  • steps companies should be taking to document and support their tax governance.

Author profile

Damian PRESHAW
Damian is Global Transfer Pricing Services Director with KPMG.
Current at 19 March 2004
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This was presented at National Transfer Pricing Conference .

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