Mr Heferen has previously worked at the ATO and also served as the deputy secretary of Revenue Group at the Treasury between 2011 and 2016, where he had responsibility for tax policy, tax legislation and revenue forecasting. Mr Jordan reflected on his 11-year tenure and was also asked about ...
The transfer pricing benefit must be assessed and negated for each tax year, not on a hindsight basis over the total loan period. The determination of arm’s length profits, and any “excessive” interest deductions, had to occur year by year. This was fundamental to how the tran...