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Branch attribution for banks presentation


This presentation covers:

  • banking landscape
  • typical structures
  • legal framework
  • current areas of focus for the ATO
  • insight from the tax avoidance taskforce (top 100 and top 1000 programs)
  • RBA vs FSE in practice – is there much difference?
  • what does this mean for taxpayers seeking assurance over branch attribution outcomes?
  • scope for Australia adopting the FSE under the Authorised OECD approach.

Author profiles

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
Click here to expand/collapse more articles by Julian PINSON.
James Campbell
James is a Director, managing the Banking and Finance Strategy in the Public Groups business line of the ATO. James has 20 years experience in compliance, audit and public advice with a focus on the banking and finance industry. Areas of expertise include capital management and hybrid financing, offshore banking units (OBUs), transfer pricing, branch attribution, controlled foreign corporations (CFCs), Part IIIB and thin capitalisation. James is currently playing a leading role in the delivery of the ATO’s Top 100 and Top 1,000 program in relation to the banking and finance industry. - Current at 18 November 2021


This was presented at 2019 Financial Services Taxation Conference .

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Future Aussie tax reform: An academic perspective

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Branch attribution for banks

Author(s):  Julian PINSON,  James Campbell

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Australia’s hybrid mismatch rules: The new goalposts for financing arrangements

Author(s):  Andrew Hirst,  Amelia Teng

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