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The art of transfer pricing : an Australan perspective.


Issue: Vol 9 No 6 2008

Pages: pp.3-12


The first part of this paper focuses on transfer pricing issues associated with intangibles and in particular marketing intangibles, which have been the subject of specific comment by the Commissioner.

The second part of this paper involves a discussion of the recent decision of Roche Products Pty Ltd v Commissioner of Taxation.

Finally, there is comment regarding the interaction between Australia's transfer pricing and customs regimes. 

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Author profiles

Fletcher Heinemann CTA
Fletch is a partner in Cooper Grace Ward Lawyers’ commercial team. Fletch specialises in tax and customs disputes. His experience includes helping clients with private rulings, audits, objections and litigation. He also assists clients by providing tax advice across a range of commercial issues. Fletch has also presented sessions at The Tax Institute’s Queensland seminars and national conferences and has published papers on topical tax and customs issues. - Current at 23 October 2018
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Paul Welch
Paul Welch FTIA joined Baker and McKenzie as a Partner in 2007, having previously been a Tax Partner at a “Big 4” accounting firm. With more than 15 years of corporate tax experience, Paul’s expertise ranges from transaction based advisory to international tax planning and transfer pricing. Paul’s client base includes closely held groups, listed multi-nationals and transaction originators - Current at 28 May 2008
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