Selected Publications by the team at TP Benchmark
At TP Benchmark, our leadership team is not only deeply experienced but also actively contributes to thought leadership in the field of transfer pricing. Below are some notable publications and presentations authored or co-authored by our experts:
In-house management of TP governance in a globalised economy
Topic: Transfer pricing governance / tax authority risk management
Forum: Taxation Institute of Australia (TIA) – Qld tax forum, 2022
Debunking common misconceptions around what constitutes a technically robust transfer pricing policy, and in turn provide practical guidance around how to better manage transfer pricing risk in-house.
Thin capitalisation & transfer pricing proposed reforms: How the TP reforms may limit debt deductions to potentially less than 30% EBITDA
Topic: Related party debt
Forum: TP benchmark – technical insights series, 2024
Overview of the amendment to Australia’s transfer pricing rules as they relate to the interaction with the thin capitalisation rules in respect of related party debt quantum.
ATO risk management – state of play
Topic: Transfer pricing governance
Forum: TP benchmark – technical insights series, 2021
Overview of the ATO’s risk management programs for relating to transfer pricing.
Thin cap and transfer pricing reform
Topic: Related party debt
Forum: CCH Learning – Training, 2023
Overview of the proposed Australian thin capitalisation reforms as at June 2023, including the amendment to Australia’s transfer pricing rules as they relate to the interaction with the thin capitalisation rules in respect of related party debt quantum.
Can’t touch this – breaking down the ATO’s intangibles PCG
Topic: Intangibles
Forum: Corporate Taxpayer Association (CTA) National Convention, 2023
Overview of the ATO’s proposed intangibles practical compliance guidelines PCG 2023/D2.
Transfer pricing – Managing the ATO’s focus on Intangible Assets
Topic: Intangibles
Forum: CCH Learning – Training, 2021
Overview of the ATO’s proposed intangibles practical compliance guidelines PCG 2021/D4.
Beginning with the end in mind: Audit ready preparedness in an evolving compliance environment
Topic: Transfer pricing governance / tax authority risk management
Forum: PwC Transfer pricing perspectives
Recommendations on the best practice for the early prevention of disputes, together with perspectives on effective audit management in selected countries in Asia. This paper is equally relevant to audit defence in Australia.
The Transfer Pricing “Reconstruction” Provisions: Recharacterising, Repricing or Reimagining
Topic: Transfer pricing legislative interpretation
Forum: Taxation Institute of Australia (TIA) – Qld tax forum, 2015
Consideration of Australia’s transfer pricing reconstruction rules, including relevant commentary and guidance as the basis for delineating between reconstruction and repricing as well as interpreting the scope of operation of the reconstruction provisions.
Reconstruction under the new transfer pricing law
Topic: Transfer pricing legislative interpretation
Forum: Taxation Institute of Australia (TIA) Blue Journal Feature Article, 2014
This article describes some of the nuances and potential ambiguity associated with the new Subdiv 815-B in the context of the requirement to reconstruct transactions.
Stapled groups and the new arm’s length income rule
Topic: Cross-staple arrangements
Forum: Taxation Institute of Australia (TIA) Journal
Overview of Australia’s non arm’s length income rules relevant to cross-staple leasing and financing arrangements involving managed investment trusts (‘MITs’).