This event was part of the Corporate Tax Club Series.
The ATO has signalled transfer pricing as a continuing area of focus, with particular controversy now attaching to the breadth of its transfer pricing powers as well as their source, treaty or statute, and the implications of both issues for the methodologies it can employ and the extent to which it can recharacterise transactions.
This event addressed the utility of profit based methods in the Australian environment after the decision in Roche Products, the approach to financing transactions in light of recent pronouncements by the Commissioner and other recent TP developments from both a taxpayer and an ATO perspective.