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  Transfer pricing Income tax 2015

The reconstruction provision in the new Australian transfer pricing rules

Source: New South Wales

Published Date: 18 Feb 2015

 

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This paper covers:

  • effect of tax treaties on the operation of the reconstruction provision
  • the "form" and "substance of commercial or financial relations between entities
  • what would independent parties dealing wholly independently have done?
  • how do reconstructed transactions affect the calculation of tax payable?
  • does section 815-140 rely on the operation of the reconstruction provisions in cases of excessive debt?
Author(s)

Individual Session

The reconstruction provision in the new Australian transfer pricing rules

Author(s): Ian Fullerton CTA
Materials from this session:

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Details

  • Published By: Ian Fullerton CTA
  • Published On:18 Feb 2015
  • Took place at:Surfers Paradise Marriott Resort & Spa

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