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Transfer pricing post Chevron paper

Published on 07 Feb 18 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This paper covers:

  • introduction and Chevron background
  • Chevron - key observations
  • outstanding questions
  • which currency.

Author profiles

Julian Humphrey CTA
Julian Humphrey, CTA, is a Partner of KPMG’s Banking and Finance practice with over 25 years experience. He works primarily with international banks and financial services companies operating in Australia, providing corporate income tax advisory and compliance services. Julian’s areas of expertise include the taxation of banks and bank branches, the taxation of financial arrangements and retail financial products as more recently the taxation of crypto currency and digital assets. He is a regular participant in consultation with the government on Australia’s tax reform proposals affecting the financial services sector - Current at 13 January 2023
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Tim Keeling
Tim Keeling is a Partner in KPMG’s International Tax Advisory practice. He has over 15 years’ of international tax experience, specialising in transfer pricing and other ‘arm’s length’ areas. During Tim’s career, Tim has worked for both the Australian Taxation Office and professional advisory firms. His experience includes managing controversy, planning and compliance matters in a wide range of industries (such as financial services, E-commerce, fast-moving consumer goods and pharmaceuticals) and transactions (including intellectual property, financial transactions, services and tangible goods). - Current at 21 January 2021
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This was presented at 2018 Financial Services Taxation Conference .

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M&A in financial services

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Residence – Central management & control

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The ATO’s approach to significant financial services tax issues

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Macro economic outlook and implications for taxation

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Australia’s hybrid mismatch rules: Application and interactions

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Tax transparency initiatives – The current state of play

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Stapled groups

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