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  Miscellaneous 2009

Profit attribution to permanent establishments and transfer pricing following the Roche case

Source: National

Published Date: 12 Feb 2009

 

The OECD finally released its Report on Attribution of Profits to PEs in July. This presentation covers:

  • so what is the ‘Authorised OECD Approach'?
  • how will it fit with the ATO's guidance on attribution of profits to PEs in Australia?
  • what are the important issues for Australian taxpayers to be aware of?

The Roche Case was Australia's first legal decision on a substantive transfer pricing matter since the introduction of Division 13:

  • what does the decision mean for taxpayers and the ATO?
  • are profit methods dead?
  • what does it mean for the financial services sector?

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Author(s)

Individual Session

Profit attribution to permanent establishments and transfer pricing following the Roche case

Author(s): Nick Houseman
Materials from this session:

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Details

  • Published By: Nick Houseman
  • Published On:12 Feb 2009
  • Took place at:Surfers Paradise Marriott Resort & Spa

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