Did you know the first Australian transfer pricing provision was introduced in 1921 largely in response to the alleged transfer pricing practices of one major international company? This company took a constitutional challenge to the legislation as far as the Privy Council.
We learnt that interesting fact from Julianne Jaques, QC, CTA, of the Victorian Bar and to find out which company caused all the ruckus, you’ll have to be sure to catch her session at our upcoming 2021 Financial Services Taxation Conference.
Julianne is one of the leading tax thinkers in Australia and has a long and impressive career to her name. In 2020, Julianne received her 25 year membership award from The Tax Institute, time she considers well-spent. In that time, she has contributed to the journals and given presentations, and also attended many conferences and other events. She was also named as the Chartered Tax Adviser of the Year at The Tax Summit in March 2020.
When she’s not working, Julianne told us she likes to “read tax cases and tax bills introduced but not passed and when I run out of these, I read exposure drafts of potential tax legislation. Isn’t that what we all do?”
Spoken like a true tax aficionado.
Related reading: Where a tax career can take you: insights from Dr Julianne Jaques
This year, we’re thrilled to have Julianne continuing her long and valued contributions to our stellar line-up of expertly driven technical events when she presents at the Financial Services Taxation Conference. Julianne will be presenting her keynote session, titled, Australia’s transfer pricing landscape to kick off day two of the event.
Julianne said that transfer pricing issues “can only increase with the increase in international groups and trade.” Which, in an increasingly global economy, means that they’re here to stay and that tax practitioners need to keep their understanding in this area sharp.
The good news? Julianne tells us that she’s finding grappling with transfer pricing very interesting.
“I’ve been briefed in a few transfer pricing matters and, sad to say, I find the area intellectually stimulating – it combines law with economics and accounting, my three majors at university. This is not to say, however, that transfer pricing is simply a battleground for expert witnesses. Ultimately, it’s necessary to take a step back and view the bigger legal picture, as clearly shown by the Full Federal Court decisions in Chevron (2017) and Glencore (2020),” she said.
The Glencore Investments decision, made in November 2020, combined with developments such as the OECD’s BEPS project and ATO practical compliance guidelines, have underlined the importance of transfer pricing management to the compliance and governance frameworks of taxpayers. In her session, Julianne will consider these kinds of recent developments with a focus on the approach that Courts have taken to transfer pricing issues and the practical implications for taxpayers in the financial services industry.
It promises to be an insightful presentation from one of the best minds working in tax today
Juliane’s parting advice for you before connecting at the Financial Services Taxation Conference was, “Be alert, be aware – not only to transfer pricing risks, but also because this is the first session on the second day of the conference.”
We’ll see you there.
Session: Session 8 Keynote: Australia’s transfer pricing landscape
Presenter: Dr Julianne Jaques, QC, CTA, Victorina Bar
When: 9.00 –10.00am, Friday, 23 April 2021 (Day 2)
Where: Join us at Crown Towers Sydney. Centrally located along the Barangaroo waterfront, with Sydney Airport located just 15 kilometres away, this brand-new hotel offers uncompromising design that captures the essence of its harbourside setting, highly intuitive personalised service, and the finest dining and facilities unlike anything Sydney has seen before.
About Dr Julianne Jaques, QC, CTA
Dr Julianne Jaques QC, CTA, is a barrister at the Victorian Bar specialising in taxation law. She has particular expertise in disputes involving complex commercial transactions and has appeared in many significant cases including Bywater and Sharpcan in the High Court. Prior to joining the Bar, Julianne spent 10 years in private practice with a major law firm and a major accounting firm. She was also senior tax adviser to the Federal Assistant Treasurer during the introduction of GST and business tax reform.