Transfer pricing and related party debt presentation

James Nickless

James has been a Partner with PwC since 2014, specialising in international tax and transfer pricing. He has advised on wide variety of cross border transactions, mergers and acquisitions, and tax controversy matters.  His unique skillset allows him to advise on cross border transactions holistically, combining international tax and transfer pricing skills.  James chairs PwC's thin capitalisation technical panel - Current at 20 January 2026

Caleb Khoo

Caleb is a Legal Partner in the PwC Australia, Tax Controversy Group. Caleb has significant experience in complex tax audits and disputes with the Australian Taxation Office. This includes litigation before the High Court of Australia, Federal Court of Australia and the Administrative Appeals Tribunal. It also includes the use of alternative dispute resolution mechanisms and settlement negotiations to resolve large and complex audits and disputes prior to and in the course of litigation proceedings. Caleb has represented large corporations across a number of industries including mining, infrastructure and construction, telecommunications and consumer goods. He has provided legal advice and services concerning the application of income tax laws, transfer pricing rules, general anti-avoidance rules, tax treaties and administrative law. He has briefed and continues to work with global industry leading experts in banking and finance in preparation for debt pricing disputes. - Current at 23 November 2017