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A new phase in transfer pricing dispute resolution in Australia podcast
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 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 27 June 2022Thomas Ickeringill
This was presented at 2021 National Transfer Pricing Conference .
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Individual sessions
BEPS 2.0: Update on Pillar 1
Author(s): Michael JENKINS, Nick MarshallMaterials from this session:
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How does transfer pricing affect customs duty and the amount of indirect taxes paid?
Author(s): Lorena Sosa, Richard NuttMaterials from this session:
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A new phase in transfer pricing dispute resolution in Australia
Author(s): Martin FRY, Thomas IckeringillMaterials from this session:
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A practical approach to financial transactions
Author(s): Frank PUTRINO, Sean MaddenMaterials from this session:
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Future trends, increased transparency and what it means for MNC businesses
Author(s): Tammy Eccles, Tony GorgasMaterials from this session:
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The ATO’s intangibles strategy and draft PCG on intangibles
Author(s): Chris FergusonMaterials from this session:
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OECD’s Pillar 2 global minimum tax proposal: Taking the pressure off transfer pricing
Author(s): Richard J VANN, Mary HuMaterials from this session:
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Provision of services or rights to use intangibles
Author(s): David BONDMaterials from this session:
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Transfer Pricing and the Application of Part IVA
Author(s): Toby KNIGHT, Anfeng HeMaterials from this session:
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Expanded definition of SGE
Author(s): Michael SMITH, Natalya MareninaMaterials from this session:
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