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SAMPLE PUBLICATIONS:

 

ENPRIS Presentation - Taxation of Financial Arrangements Stages 3 and 4, UNSW School of Business Law and Taxation, Australian School of Business; Sydney, Australia, Jun 2009

 

ENPRIS Submission - IASB/FASB Tokyo Roundtable on the Global Financial Crisis, Dec 2008

 

ENPRIS Presentation - ASEAN Conference, Challenges and Perspectives - Extracting Value from IP, Siem Reap, Cambodia, Nov 2007

ENPRIS Taxation

ENPRIS Taxation Brochure

ENPRIS Pty Limited has extensive experience in the administrative application and active compliance relating to of the taxation law relating to the taxation of financial arrangements, financial products, financial transactions and valuation of businesses, securities, financial products, derivatives, intellectual property and intangible assets, having been engaged by the Australian Taxation Office (ATO) since 2004.

This experience includes the provision of specialist advice to the ATO on the implementation of TOFA Stages 3 & 4 (Division 230 of the Income Tax Assessment Act 1997).

ENPRIS is a Registered Tax Agent (Tax Agent Licence No. 82986006).

ENPRIS provides taxation advice in a number of areas including the following:

Taxation compliance - Large Business and International segment taxpayers

Assistance provided across all areas of the active compliance framework, including the following:

-Effectively communicating commercial and business rationale and strategies with the ATO through the ATO's cooperative compliance model

-Risk Differentiation Framework (RDF) ratings and risk filters

-Preparation of Reportable Tax Positions schedule (RTP)

-Preparation of Reasonable Arguable Position papers (RAPs)

-Addressing Part IVA counterfactuals presented by the ATO

-Preparation of ATO Compliance Questionnaires

-Negotiation and implementation of Annual Compliance Arrangements with the ATO

Taxation of financial products & arrangements

-Implementation of Division 230 of the ITAA 1997

-Compliance assistance in relation to the application of Division 230 of the ITAA 1997

-Interpretation and technical application of Division 230 of the ITAA 1997

-Valuation, pricing and characterisation of financial products and derivatives and the application and workings of domestic and international financial markets; in the context of the interpretation, administration and application of the law

-Application and interpretation of international accounting standards and practices to taxation law

Valuations for taxation purposes

-Implementation of the Mining Resource Rent Tax (MRRT)

-Advice regarding the ATO's Valuation practices and processes

-Advice in relation to the ATO's Interpretative Advice (IA) function covering products such as class rulings, private rulings, market valuation rulings and Commissioner's discretion

-Advice in relation to the ATO's active compliance products and functions including client risk reviews, consolidation reviews, specific issue audits and large business audits

Transfer Pricing

-Valuation of intangible assets and intellectual property

-Pricing of services provided between international parties

-Advice re foreign bank profit allocations

-Pricing of intragroup loans & guarantees

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