This seminar will discuss the development of transfer pricing jurisprudence in Australia and Canada through the lens of key landmark decisions in each country. This seminar will also consider the transfer pricing focus areas of the Australian Taxation Office and the Canada Revenue Agency, highlighting similarities and differences in approaches.
Speakers:
Mikael Johansson, PwC Law LLP, Canada
Danielle Ou, Arnold Bloch Leibler, Australia
Moderators:
Anfeng He, Allens, Australia
Alexandre Mercier, PwC LLP, Canada
SPEAKER
Danielle is a lawyer at Arnold Bloch Leibler in the Sydney taxation practice and was previously a member of Ernst & Young’s transfer pricing teams in both New Zealand and Australia. Her practice includes advising on international tax and transfer pricing matters and representing clients in tax audits and disputes with the Australian taxation office. Her clients include a wide range of listed and private multinational groups.
SPEAKER
Mikael is a tax lawyer with PwC Law LLP in Calgary. His practice focuses primarily on tax dispute resolution. Mikael frequently represents clients at the audit, objection and appeal stages of transfer pricing disputes with the Canada Revenue Agency.
MODERATOR
Anfeng advises taxpayers on a broad range of corporate tax issues, with significant experience in both advisory and disputes.
In his advisory work, Anfeng helps taxpayers navigate the Australian income tax implications of their transactions and business structures. In his disputes work, Anfeng assists taxpayers with the full ambit of tax disputation. He regularly manages audits, information requests and evidence gathering, all towards the goal of resolution, whether by a favourable audit outcome, strategic settlement, or resolution via litigation.
MODERATOR
Alexandre is a Transfer Pricing and Value Chain Transformation Director with PwC Canada. He has over a decade of transfer pricing experience, including 3 years in Chicago, USA. Alexandre's expertise covers end-to-end services including planning, documentation, Advance Pricing Arrangements, as well as controversy related to transfer pricing. He provides transfer pricing services to clients in various industries, including pharmaceuticals, retailing, natural resources/chemicals, industrial manufacturing, financial sector and the technology sector.
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