David Lewis

Dave Lewis joined Deloitte in November 2002 after a career in the Australian Taxation Office (ATO) spanning 38 years.
Dave is best known for his work on transfer pricing. In 1994, he was appointed Assistant Commissioner International Compliance and Strategy. The key task of this position was as Australia's Competent Authority where he had responsibility for international relationships, Exchange of Information and the Mutual Agreement Procedures. Dave led Australia's delegation in key international meetings such as the Pacific Association of Tax Administrators (PATA), the OECD's Working Party 8 on Tax Avoidance and Evasion and the OECD Forum on Harmful Tax Practices.
Dave had responsibility for the ATO's transfer pricing program. He chaired the National Tax Liaison Group (Transfer Pricing Sub-Committee). This forum allowed transfer pricing practitioners have input on ATO policy and practice. He introduced changes in procedure that have made the APA program more user-friendly. These changes and his personal promotion of the APA program led to a substantial increase in the number of companies seeking and successfully concluding APAs. He also introduced quality control measures on proposed audit adjustments and APAs to ensure that they aligned with the ATO's published view. The transfer pricing compliance strategy he introduced still forms a key component of the current ATO approach.
In respect to Mutual Agreement Procedures, Dave personally led many of the negotiations with other tax authorities on double tax cases, especially those with USA and Japan. He achieved considerable success in alleviating double taxation and settling bilateral APAs. Dave was also instrumental in considerably reducing the time frame to achieve consensus. He changed ATO practice to ensure that taxpayers were kept informed and as much as possible involved in of the progress of their MAP and bilateral APA cases. His leadership fostered confidence in ATOs capacity to achieve fair outcomes in these settlements.
Since joining Deloitte Dave has played a key role in resolving Audit and APA cases. His understanding of the approach of the ATO and other tax administrations to significant transfer pricing issues has been invaluable in achieving the best outcome for our clients. The knowledge he has transferred to Deloitte personnel has improved the capability of our practice to deliver quality advice to clients and to successfully advocate our clients' position in MAP and APA applications.

Bloomberg BNA Tax Management Portfolios:
6940 T.M., Transfer Pricing: Rules and Practice in Selected Countries (A-B) (co-author)