This presentation covers the distinction between the provision of services and the granting of rights to use intangibles in interactions between members of MNE groups.
David is a Partner at Partner at Greenwoods & Herbert Smith Freehills and is the national leader of their transfer pricing practice. David has over 30 years of transfer pricing and international tax experience and previously worked in a Big 4 firm in their Perth, Melbourne and Chicago offices. David has experience in advising multinationals on a broad range of transactions and industries but has particular expertise in the Energy & Natural Resources sector and their common cross border transactions of finance, sales of commodities, sharing of intellectual property, and services. David has assisted clients with various ATO interactions including ruling requests, reviews, audits, and providing support for tax and transfer pricing litigation. He has also assisted clients in negotiating unilateral and bilateral Advanced Pricing Agreements. David provides income tax advice on a range of domestic and international transactions, including issues associated with debt funding, royalties, and tax consolidations
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11 June 2021