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Transfer Pricing and the Application of Part IVA paper


This paper covers questions that might arise from the intersection of transfer pricing and Part IVA.

Author profiles

Toby Knight CTA
Toby is a Tax Partner at Allens. He practises in corporate and international tax with particular expertise in dispute resolution, audits, transfer pricing, research and development, and tax litigation. He advises on mutual agreement procedures, tax treaty and structuring issues in transfer pricing matters and has over 17 years of experience in acting for many leading companies in a wide range of significant audits and tax litigation. These have included disputes in relation to capital gains tax, complex restructures and tax consolidation, Part IVA, foreign exchange transactions, franking credits and the application of different transfer pricing methodologies. - Current at 13 November 2013
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Anfeng He FTI
Anfeng He, FTI, is a Senior Associate at Allens. He advises taxpayers on a broad range of corporate tax issues, with a focus on advisory and disputes. In his advisory work, Anfeng helps taxpayers navigate the Australian income tax implications of their transactions and business restructures. In his disputes work, Anfeng assists taxpayers with the full ambit of dispute resolution, from audit to litigation. His recent experience includes litigation in the Federal Court and advising on the conduct and settlement of a long standing transfer pricing dispute with the ATO. - Current at 12 May 2021
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This was presented at 2021 National Transfer Pricing Conference .

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