Bill Yohana

Executive summary

Bill is a BDO Transfer Pricing Partner based in Melbourne, holding a national position. Bill specialises in providing clients with financial services and financial transactions transfer pricing advice, with over 25 years of transfer pricing experience earned in Australia and the United States. In delivering his advice, Bill draws upon nine years of front office experience in the financial services sector, gained in institutional investment management, interest rate derivatives structuring and marketing, and evaluating payments system risk.

Bill has assisted clients with taxation authority audits in several jurisdictions, including Australia, the U.S., and the U.K., including developing strategies to respond to a revenue authority audit, preparing responses to revenue authority position papers, and being engaged to provide ‘expert’ analysis. In this work, Bill combines his formal training in finance, his work in the financial markets and his extensive experience in providing clients with transfer pricing advice.

Expertise

• Financial transactions transfer pricing across industry sectors: financial services, resources, real estate, and other sectors with intra-group debt financing, focusing on complex and material transactions and estimating arm’s-length interest rates and capital structures (i.e., thin capitalisation/debt capacity) for multinational groups and their subsidiaries.
• Financial services transfer pricing: advising banks, securities firms, traditional asset managers, hedge funds, private equity firms, family offices, insurers, fintech firms and real estate investors.

Experience

• Develop a cash pooling policy for a major software as a service provider.
• Establish arm’s-length pricing for intra-group loans to subsidiaries of a significant medical products provider.
• In connection with a revenue authority audit, determined arm’s-length ‘breakage fees’ for outstanding intra-group debt. Estimation of market-based premia for intra-group callable debt.
• Estimate market-based interest rates for loans to finance major projects in developing countries.
• As part of a revenue authority audit, prepared an analysis that established that interest rate derivative contracts between a European bank and an overseas subsidiary were priced on market.
• As part of statutory audits, evaluated the tax risk associated with intra-group financial transactions and transfer pricing policies.
• Prepare transfer pricing documentation across service lines for central U.S. and European banks.
• Prepare transfer pricing documentation for a hedge fund engaged in insurance-related transactions.
• Evaluate investment management fees charged to a family office by a related offshore investment manager.

Qualifications and affiliations

• Bachelor Degree in Economics
• Master of Business Administration
• Chartered Financial Analyst
• Associate, Tax Institute of Australia