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Alternative assets insights: Stapled groups and the new arm’s length income rule

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Published on 01 Dec 15 by "TAXATION IN AUSTRALIA" JOURNAL ARTICLE

This article discusses the application of transfer pricing principles to cross-staple leasing structures under the non-arm’s length income rule in the proposed new tax regime for managed investment trusts.

Author profiles

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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Benjamin Lannan
Ben is a Partner in PwC's Transfer Pricing practice, based in Brisbane and a member of PwC's Global Transfer Pricing network. Ben has over 16 years experience in transfer pricing, assisting a range of clients to develop and implement defendable transfer pricing strategies. Ben regularly speaks on transfer pricing at events. Ben has a Bachelor of Economics from Monash University and is a member of the Institute of Chartered Accountants. - Current at 30 April 2015
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Dritton Jemaylay
Dritton is Director – Transfer pricing PricewaterhouseCoopers.
Current at 1 December 2015

 

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