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Related party financing paper

Published on 26 Oct 17 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This paper covers:

  • Chevron
  • Draft Practical Compliance Guideline 2017/D4
  • what does this mean practically for how a taxpayer should establish and defend related party financing going forward?
  • other related party financing issues for consideration.

Author profiles

Peter Collins FTI
Peter Collins, FTI, is a Partner at PwC with 30 years experience as a specialist in global tax, assisting foreign investors structuring their Australian investments and Australian corporates expanding offshore. He works with the firm’s global tax network to develop solutions for clients and is a member of the International Tax executive, which allows him to provide a unique global perspective. - Current at 15 June 2022
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Caleb Khoo
Caleb is a Legal Partner in the PwC Australia, Tax Controversy Group. Caleb has significant experience in complex tax audits and disputes with the Australian Taxation Office. This includes litigation before the High Court of Australia, Federal Court of Australia and the Administrative Appeals Tribunal. It also includes the use of alternative dispute resolution mechanisms and settlement negotiations to resolve large and complex audits and disputes prior to and in the course of litigation proceedings. Caleb has represented large corporations across a number of industries including mining, infrastructure and construction, telecommunications and consumer goods. He has provided legal advice and services concerning the application of income tax laws, transfer pricing rules, general anti-avoidance rules, tax treaties and administrative law. He has briefed and continues to work with global industry leading experts in banking and finance in preparation for debt pricing disputes. - Current at 23 November 2017
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James Nickless
James Nickless is a tax partner specialising in transfer pricing and international tax at PwC. James has significant experience advising on cross-border funding structures from a transfer pricing and international tax perspective. James has advised a variety of infrastructure investors in relation to their capital structures as well as cross-staple lease pricing.James has been involved with the ATO and Treasury consultation process in relation to guidance on related party debt arrangements, the diverted profits tax and anti-hybrid rules. James is a Member of Chartered Accountants Australia & New Zealand. - Current at 05 May 2018
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