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A new phase in transfer pricing dispute resolution in Australia presentation


This presentation 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 2022
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Thomas Ickeringill


This was presented at 2021 National Transfer Pricing Conference .

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