Published on 09 Sep 21
by NATIONAL DIVISION, THE TAX INSTITUTE
This paper covers questions that might arise from the intersection of transfer pricing and Part IVA.
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
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