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Alternative assets insights: PCG 2019/D3: A way forward on the ALDT

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Published on 01 Oct 19 by "TAXATION IN AUSTRALIA" JOURNAL ARTICLE

The latest ATO guidance suggests that a detailed robust analysis, along with corresponding evidence, is key to satisfying the arm’s length debt test.

Author profiles

Edwin Baghdasarayan ATI
Edwin is a Transfer Pricing Partner within the PwC Australia Global Tax practice, based in Sydney. He has also spent time with the US firm in New York as well as the New Zealand firm in Auckland. He has practiced transfer pricing at PwC since 2007 and has been involved in assisting numerous Australian and foreign listed multinationals in their global transfer pricing across the entire lifecycle including consulting, structuring and planning, documentation, managing risk reviews, audits and APAs. His experience ranges across a variety of industries, including financial services, consumer & industrial products, resources, logistics/transport and the technology sector. - Current at 23 May 2022
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Nick Houseman
Nick Houseman FTIA is a Partner in Transfer Pricing at PricewaterhouseCoopers, Sydney. Nick has over 15 years experience advising on transfer pricing matters with a focus on the financial services sector. Nick also has extensive experience in local and global transfer pricing documentation and compliance, tax planning, negotiations of Advance Pricing Agreements, competent authority negotiations, litigation support and audit defence in the financial services industry and other industries for well known Australian and foreign companies. Nick has managed many significant regional and global projects based in Asia-Pacific and European regions and has conducted many in-depth financial and economic analyses throughout the financial services industry. - Current at 01 January 2014
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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
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