Become a Member
Membership
Education
Events
Resources
Tax Knowledge Exchange
About us
Contact us
  Miscellaneous 2009

Profit attribution to permanent establishments and transfer pricing following the Roche case

Source: National

Published Date: 12 Feb 2009

 

Sorry, this is subscriber only content.

If you're not yet a subscriber, to gain access to this material and much more - Subscribe Now.

Already a Subscriber? Login now

Subscribe Now

Already a Subscriber? Login now

The OECD finally released its Report on Attribution of Profits to PEs in July. This paper covers:

  • so what is the ‘Authorised OECD Approach'?
  • how will it fit with the ATO's guidance on attribution of profits to PEs in Australia?
  • what are the important issues for Australian taxpayers to be aware of?

The Roche Case was Australia's first legal decision on a substantive transfer pricing matter since the introduction of Division 13:

  • what does the decision mean for taxpayers and the ATO?
  • are profit methods dead?
  • what does it mean for the financial services sector?
Author(s)

Individual Session

Profit attribution to permanent establishments and transfer pricing following the Roche case

Author(s): Nick Houseman
Materials from this session:

Download

Details

  • Published By: Nick Houseman
  • Published On:12 Feb 2009
  • Took place at:Surfers Paradise Marriott Resort & Spa

The material is copyright. Apart any fair dealing for the purpose of private study, research criticism or review, as permitted under the copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.

Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

The Tax Institute
(ABN 45 008 392 372 (PRV14016))

("TTI")

The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009. 

Copyright Statement

All materials provided on this site are protected by copyright and are owned by or licensed to TTI.

Except as expressly permitted by TTI or the copyright owner, any person or company who uses this site must not use, reproduce, redistribute, retransmit, publish or otherwise transfer, or commercially exploit, the materials or any information, software or other content, in whole or in part, which is available through this site.

Tags

Miscellaneous 2009

Share this page