Philip Diviny

Philip Diviny

K&L Gates LLP

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Action 6 – Preventing the Granting of Treaty Benefits in Inappropriate Circumstances

Action 6 of the BEPS Action Plan identified treaty abuse as one of the most important sources of BEPS concern. The report offers alternative model provisions for the prevention of treaty abuse given constitutional and other...more

11/20/2014 - Australia BEPS International Treaties

Base Erosion and Profit Shifting: The Australian Perspective

In July 2013, the G20 Finance Ministers, including Australia, fully endorsed the base erosion and profit shifting (BEPS) Action Plan. As a result of the Action Plan, the Australian government encouraged a new commitment to...more

11/20/2014 - Australia BEPS G20 OECD

It’s Like Déjà Vu – All Over Again – NSW Defers the Abolition of Stamp Duty

Abolition of NSW duties deferred again - The NSW Government has indicated that the abolition of Inter-Governmental Agreement taxes, including duties on: - marketable securities (shares and units) - ...more

5/2/2013 - Duties Mortgages Proposed Legislation Securities Stamp Duty Land Tax

Government Releases New Transfer Pricing Measures to Attack Multinationals

On 13 February 2013, the Federal Government introduced legislation into Parliament that will significantly broaden the circumstances in which Australia's transfer pricing rules may be applied. The legislation will come...more

2/21/2013 - Arm's Length Principle Multinationals Mutual Agreement Procedure OECD Required Documentation Transactional Net Margin Method Transfer Pricing

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