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Reconstruction or recharacterisation under transfer pricing – arguments for and against video


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Publication date: 18 Oct 21 | Source: NATIONAL DIVISION, THE TAX INSTITUTE


Abstract:
This video covers the relevant provisions in Division 815, the OECD Guidelines and recent Court decisions which focus on these issues.

Author profiles

David Bond CTA
David is a Tax Partner at PwC. David has over 32 years of transfer pricing and international tax experience and has worked in Perth, Melbourne, and Chicago. David has experience in advising multinationals on a broad range of transactions and industries but has particular expertise in the Energy & Natural Resources sector and the industries common cross border transactions of finance, sales of commodities, sharing of intellectual property, and services. David has assisted clients with various ATO interactions including ruling requests, reviews, audits, and providing support for tax and transfer pricing litigation. He has also assisted clients in negotiating unilateral and bilateral Advanced Pricing Agreements. David also provides income tax advice on a range of domestic and international transactions, including issues associated with debt funding, royalties, and tax consolidations. - Current at 30 November 2022
Fiona Dillon CTA
Fiona Dillon, CTA, is the ATO’s Chief Tax Counsel, accountable for the ATO’s public advice and guidance, litigation, and resolving the ATO’s most significant tax technical issues. Fiona previously served as Minister-Counsellor (Taxation) in the Australian delegation to the OECD based in Paris and spent a number of years in private practice. Fiona is an admitted Australian legal practitioner and holds a Bachelor of Commerce, Bachelor of Laws with Honours, and a Master of Taxation. - Current at 27 May 2024
Dioni Perera
Click here to expand/collapse more articles by Dioni Perera.
This was presented at The Tax Summit .

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