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The Benchmark archive

The Benchmark

October 2011
  • Latest news on OECD project on transfer pricing aspects of 'intangibles'
  • Joint seminar by ATO and Japan NTA highlights good working relationship on transfer pricing
  • ATO releases draft International Dealings Schedule and instructions.
September 2011
  • The ATO approach to commercial realism: time for a rethink?
  • New ATO paper on profit allocation to bank branches
July 2011
  • New ATO Reportable Tax Position schedule
  • ATO released 2011-12 compliance program
  • The SNF case: where to now?
May 2011
  • The effects of the rising Australian dollar on your transfer prices
  • New OECD project on administration of transfer pricing.
April 2011
  • Transfer pricing implications of proposed changes to Controlled Foreign Company (CFC) rules
  • National Tax Liaison Group (NTLG) Transfer Pricing Sub-group update
  • The SNF case appeal.
March 2011
  • APAs given new life in Australia
  • ATO commences first transfer pricing "Joint Audits"
  • OECD releases scoping document for its intangibles project.
February 2011
  • Taxation Ruling TR2011/1
  • Business Restructuring: no changes from the ATO.
December 2010
  • ATO's Strategic Compliance Initiative
  • Business restructures
  • The ATO's focus on financial arrangements
  • Transfer pricing litigation – the SNF Australia case
  • International dealings schedule.
November 2010
  • Latest ATO developments
  • Australian APA program booming
  • New domestic arm's length dealing rule for MITs
  • Global.DoX.
October 2010
  • OECD to revise guidance on intangibles
  • ATO update on transfer pricing for large business
  • Industry data used by ATO to assess transfer pricing risk
  • Application of the arm's length principle to the minerals resource rent tax.
September 2010
  • Is the TNMM still a viable approach for taxpayers in Australia?
  • Update on the ATO's strategic compliance initiative
  • Update on the ATO's 'rule of thumb' approach to the pricing of inbound intra group loans
  • China developments – transfer pricing documentation inspections and business restructures.
August 2010
  • OECD Guidelines receive a facelift
  • NTLG developments
  • Transfer pricing remains a major area of focus in the ATO's compliance program
  • Welcome back Marc Simpson.
July 2010
  • Profit-based methods sidelined again by Australian court
  • Revised ruling on pricing of international financing arrangements
  • Transfer pricing flagged by ATO as key compliance risk.
June 2010
  • ATO ruling on business restructures
  • Spotlight on transfer pricing developments in China
  • GE Capital case – grounds of appeal explored.
May 2010
  • Government's response to Henry Review will do little to improve Australia's competitiveness
  • ATO consults on an alternative 'rule of thumb'
  • Moving towards a higher level of global cooperation
  • Introducing Jonathon Bernsen - another new Transfer Pricing partner for Deloitte!
April 2010
  • GFC impact on profit benchmarking
  • The latest from the ATO on transfer pricing matters
  • Spotlight on transfer pricing documentation requirements in Japan
  • Introducing Bill Yohana.
March 2010
  • Resources sector is the latest ATO target
  • Tough times ahead for taxpayers with 'uncertain tax positions'
  • Are you prepared for a transfer pricing audit in China?
  • Transfer pricing still on the radar in Europe.
February 2010
  • Strategic Compliance Initiative - ATO's transfer pricing project
  • Financing - intra group loans and guarantee fees
  • Draft Taxation Ruling TR 2009/D6 - interaction of thin capitalisation and transfer pricing provisions
  • Rule of thumb PS LA 3187
  • Final international dealing schedule reflects feedback from industry and professional bodies
  • Deloitte partners listed as Australia's leading transfer pricing advisers.
December 2009
  • ATO's Strategic Compliance Initiative – 140 transfer pricing questionnaires to be sent in the new year
  • Further ATO commentary on intra-group financing due later this month
  • GE Capital Canada wins guarantee fee case
December 2009
Special Edition
  • Draft taxation ruling - TR 2009/D6
  • Draft practice statement - PS LA3187
November 2009
  • ATO to issue Practice Statement on 'Rule of thumb' approach for pricing of intra-group loans
  • Guarantees within multinationals – a timely visit to Australia for global expert
  • LBAG continue the debate on draft international dealings schedule
  • ATO crackdown on employee share scheme recharges
October 2009
  • ATO begins revised risk assessment approach by collecting new information
  • OECD elevates status of profit-based methods
  • ATO releases 2008-09 APA Program, with commentary on the global financial crisis 
  • New accounting standard requires certainty on transfer pricing.
September 2009
  • Are you prepared for the ATO?
  • Australian transfer pricing litigation update
  • Chinese tax authorities focus on losses 
  • Welcome Jacques Van Rhyn
August 2009
  • Commissioner of Taxation addresses - Deloitte's Tax perspective event
  • 'Rule of thumb' proposal for pricing of intra group loans
  • New Australia - New Zealand tax treaty
  • New ATO International Dealings Schedule
July 2009
  • ATO steps up investment in APA program
  • Maximising fiscal gains & shareholder returns: ATO announcements
  • Highlight conflicts in a common goal
  • OECD holds consultation with business on restructuring
  • Commentary on double taxation relief indicative of Hong Kong's ambitions?
June 2009
  • A "Transfer Pricing Review" of the Australian federal budget: against the backdrop of the Henry review and the current global transfer pricing landscape
  • Welcome news on unlimited amendment periods
  • ATO's Transfer Pricing consultative committees
May 2009
  • Transfer pricing for financing – more than LIBOR plus a margin?
  • BHP Billiton Finance Limited v Federal Commissioner of Taxation
  • New Zealand's IRD announces focus on issues arising from recent economic events
April 2009
  • Deloitte's response & public comments on the OECD's business restructures paper
    – risks and opportunities in an economic downturn
  • New Zealand's IRD announces increased focus on related-party IP licensing transactions
  • The Guardian investigation of multinationals
  • Carbon Pollution Reduction Scheme – international linking opportunities
March 2009
  • Transfer pricing - risks and opportunities in an economic downturn
  • The ATO's response
  • Short-term strategies
  • Medium to longer term-planning
February 2009
  • Decision Impact Statement: ATO views on the Roche case
  • IRS releases proposed and temporary cost share regulations
  • China developments - thin capitalisation rules and documentation requirements
  • ATO's APA program review – update
December 2008
  • Transfer pricing in the courts
  • Policy developments
  • Transfer pricing on the ATO's radar again
  • Looking ahead . . .
November 2008
  • Advance pricing arrangement (APA) program review
  • The credit crisis and debt pricing
  • ATO to set up SME compliance activities
  • Transfer pricing rules allow shifting of business losses to Australia.
October 2008 
  • Transfer pricing matter before the Federal Court
  • transfer pricing at the OECD
  • Deloitte's global financial services industry expert in Australia 
  • China issues new Circular regarding intercompany services.
September 2008 
  • OECD releases draft discussion paper on business restructures
  • ATO continues its focus on use of trust arrangements by partnerships
  • Asian governments continue to step up their enforcement of transfer pricing.
August 2008 
  • High Court releases its judgment in WR Carpenter
  • Singapore introduces transfer pricing reviews
  • OECD approves 2008 update to the Model Tax Convention
  • facts and figures.
August 2008 - special edition 
  • ATO released Annual Compliance Program statement for the 2008-09 fiscal year
June 2008 
  • GlaxoSmithKline in Canada – transactional methods again
  • GE Canada – judgment relevant to commercial purpose and transfer pricing
  • new Schedule 25A 2008 form released by the ATO
  • facts and figures.
June 2008 - special edition 
  • ATO discussion paper – intra-group finance guarantees and loans
  • specific issues.
May 2008 
  • ATO discussion draft on debt pricing and guarantee fees
  • annual compliance arrangements
  • IRS APA procedure now covers permanent establishments and other issues
  • facts and figures.
April 2008
  • Roche case – further considerations
  • National Tax Liaison Group (NTLG) transfer pricing sub-group meeting
  • ATO discussion paper on debt pricing and guarantees
  • facts and figures.
 
  • judge rules transfer pricing adjustments for an Australian distributor of a large foreign owned MNC of A$58M
  • background
  • the preliminary judgement
  • transfer pricing analysis – not just a valuation exercise
  • tips & takeaways.
March 2008 
  • draft TD regarding interaction of Division 974 and Division 13
  • the competent authority process
  • US IRS releases paper on cost-sharing stock-based compensation
  • facts and figures.
February 2008 
  • new Chinese transfer pricing rules – effective 2008
  • new Australia-Japan tax treaty
  • withdrawal of ATOID – foreign branch transactions and the single entity rule
  • facts and figures.
January 2008 
  • ATO and business restructures – in the news again
  • transfer pricing priorities in New Zealand in 2008
  • guarantee fees – another case in Canada
  • facts and figures.
January 2008 - new year edition 
  • Deloitte workshop on guarantee fees and related financing issues
  • summary of the Benchmark: July – November 2007
  • facts and figures.
November 2007 
  • revised OECD discussion draft on attribution of profits to permanent establishments (PEs) in the insurance industry
  • APA program review – update
  • interaction of Australia's thin capitalisation and transfer pricing provisions – issue of a draft Taxation Determination
  • customs and transfer pricing
  • facts and figures.
October 2007 
  • improvements in process for relief from double taxation
  • ATO annual advance pricing arrangement (APA) program update
  • external review of the advance pricing arrangement (APA) program
  • facts and figures.
September 2007
  • intercompany loan guarantees – a wave of controversy looming?
  • review of unlimited amendment periods for transfer pricing
  • ATO releases fifth annual report on APA program
  • facts and figures.
August 2007
  • ATO's business restructuring discussion paper
  • FIN 48 developments
  • Keith Reams joins the Australian Deloitte team
  • facts and figures.
August 2007 - special edition
  • transfer pricing and the 2007-08 ATO compliance program
  • facts and figures.
July 2007
  • transfer pricing – renewed focus on global restructures and foreign bank branches in Australia
  • 2007 Schedule 25A released
  • David Grecian joins Deloitte
  • facts and figures.

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