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Branch attribution paper

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DisclaimerThis material is copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
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 08 Feb 17 by NATIONAL DIVISION, THE TAX INSTITUTE

This paper covers:

  • timeline of key documents/events
  • current Australian law and ATO practice
  • RBA vs. AOA
  • international comparison
  • ATO focus areas in bank PE attribution
  • current practical issues and risks, including transfer pricing methodologies.

Author profile

Julian Pinson FTI
Julian is a Partner at Greenwoods & Herbert Smith Freehills Pty Limited. Julian advises on a wide range of tax matters, with a focus on banking and financial services, property, M&A and funds management. Julian has particular expertise in cross-border finance, TOFA, corporate restructures, debt and equity raisings and M&A. - Current at 22 November 2021
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This was presented at 2017 Financial Services Taxation Conference .

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Recent cases and rulings

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Transfer pricing and financial services organisations

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Automatic exchange of information and the common reporting standard from the perspective of Australian financial institutions

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Perspectives: Future directions in corporate tax

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Areas of focus for the financial services industry

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Author(s):  Tony FROST,  Bob HERBERT

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Latest on the superannuation and related tax issues (large funds)

Author(s):  Bevan Grace

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Branch attribution

Author(s):  Julian PINSON

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The Second Johnson Report - A stocktake on banking recommendations

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Transaction costs and M&A deals

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The Board of Taxation

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