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A new phase in transfer pricing dispute resolution in Australia podcast

Member Price: $35.00
Non Member Price: $43.00

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Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

Published on 09 Sep 21 by NATIONAL DIVISION, THE TAX INSTITUTE

This podcast covers:

  • The role that your evidence can play in a domestic court strategy relative to a MAP strategy in light of Glencore
  • The impact of a multinational group’s domestic dispute resolution strategy (i.e., to settle or to litigate) on potentially achieving a resolution via MAP/arbitration
  • For both the multinational taxpayer and the ATO, the tension between preserving rights under domestic tax laws and achieving resolution via MAP / arbitration
  • The impact of mandatory binding arbitration on the prospects of achieving resolution via MAP; and
  • The OECD’s desire to change the dialogue from ‘dispute resolution’ to ‘dispute prevention’ and what this might mean for multinational groups’ dispute resolution strategies in the future.

Author profiles

Martin Fry FTI
Martin Fry, FTI, is the Practice Leader of the Allens Tax Group. With over 20 years as a Partner of Allens, Martin advises corporations on a broad range of tax issues across a wide range of sectors, including resources, infrastructure, financial services and IP-intensive businesses. In recent years, Martin has focused on contentious transfer pricing matters, including audits, settlement negotiations, mutual agreement procedure and litigation. Martin has taught Corporate Tax at a postgraduate level at the University of Melbourne. - Current at 12 May 2021
Click here to expand/collapse more articles by Martin FRY.
Thomas Ickeringill

 

This was presented at 2021 National Transfer Pricing Conference .

Get a 20% discount when you buy all the items from this event.

Individual sessions

BEPS 2.0: Update on Pillar 1

Author(s):  Michael JENKINS,  Nick Marshall

Materials from this session:

How does transfer pricing affect customs duty and the amount of indirect taxes paid?

Author(s):  Lorena Sosa,  Richard Nutt

Materials from this session:

A new phase in transfer pricing dispute resolution in Australia

Author(s):  Martin FRY,  Thomas Ickeringill

Materials from this session:

A practical approach to financial transactions

Author(s):  Frank PUTRINO,  Sean Madden

Materials from this session:

Future trends, increased transparency and what it means for MNC businesses

Author(s):  Tammy Eccles,  Tony Gorgas

Materials from this session:

The ATO’s intangibles strategy and draft PCG on intangibles

Author(s):  Chris Ferguson

Materials from this session:

OECD’s Pillar 2 global minimum tax proposal: Taking the pressure off transfer pricing

Author(s):  Richard J VANN,  Mary Hu

Materials from this session:

Provision of services or rights to use intangibles

Author(s):  David BOND

Materials from this session:

Transfer Pricing and the Application of Part IVA

Author(s):  Toby KNIGHT,  Anfeng He

Materials from this session:

Expanded definition of SGE

Author(s):  Michael SMITH,  Natalya Marenina

Materials from this session:

Further details about this event:

 

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