Articles

Advance pricing arrangement reform in Australia: Was it worth the wait?, Intertax (2012)

In June 2007, the Australian Taxation Office (ATO) announced that it had tendered for an...

 

Are advance pricing agreements the transfer pricing controversy management tool of the future?, Australian Tax Review (2011)

This article examines the worldwide changes that have taken place in relation to transfer pricing...

 

Congruence and divergence in transfer pricing in Australia and Japan: Intangibles and advance pricing agreements, Asia-Pacific tax bulletin (2009)

This article compares and contrasts the approaches taken by Australian and Japanese tax authorities in...

 

APAs in Australia, Canada and the United States: Current developments and future directions, Intertax: International tax review (2006)

Australia, Canada and the United States have all, in recent years, introduced more severe penalties...

 

Tax in a changing world: The transfer pricing of intangible assets, Tax notes international (2005)

While transfer pricing has risen to the forefront of international tax issues in the last...

 

The advantages and disadvantages of using an advance pricing agreement: Lessons for the UK from the US and Australian experience, Intertax: International tax review (2005)

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The requirement in many OECD countries for 'contemporaneous documentation' of a taxpayer's transfer...

 

The resolution of transfer pricing disputes through arbitration, Intertax: International tax review (2005)

Because transfer pricing is an inexact and extremely complex science, it is possible for the...

 

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Transfer pricing of intangible assets in the US, the OECD and Australia: Are profit-split methodologies the way forward?, University of Western Sydney law review (2004)

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In the 21st century, the number one international tax issue of interest to...

 

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Complying with Australian and PATA Transfer Pricing Documentation Rules - A Sisyphean Task?, Revenue Law Journal (2004)

With the increase in international trade, revenue authorities are taking an aggressive approach to transfer...

 

Books

Advance pricing agreements: Past, present and future, Advance pricing agreements: Past, present and future (2012)

Transfer pricing (the pricing of cross-border intra-firm transactions between related parties) is now the top...

 

The transfer pricing of intangibles (2005)

Transactions involving intellectual property play an increasingly significant role in economic activity at every level...