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The ATO has published a Decision Impact Statement in relation to the decision of the Full Federal Court in FCT v SNF Australia Pty Ltd [2011] FCAFC 74; 2011 ATC 20-265; 193 FCR 149.

The case concerned whether the taxpayer paid more than the arm's length price for products acquired from overseas related parties so that the Commissioner could apply the transfer pricing rules to adjust the purchase price for income tax purposes. The Full Federal Court found for the taxpayer.

The Government has announced that it intends to introduce legislation to reform the transfer pricing rules. Subject to the need to give effect to any amending legislation, the Commissioner will consider whether changes ought to be made to his public rulings in light of the Court's decision, including these:

  • Taxation Ruling TR 94/14 - Income tax: application of Division 13 of Part III (international profit shifting) - some basic concepts underlying the operation of Division 13 and some circumstances in which s 136AD will be applied
  • Taxation Ruling TR 97/20 - Income tax: arm's length transfer pricing methodologies for international dealings
  • Taxation Ruling TR 2010/7 - Income tax: the interaction of Division 820 of ITAA 1997 and the transfer pricing provisions
  • Taxation Ruling TR 2011/1 - Income tax: application of the transfer pricing provisions to business restructuring by multinational enterprises


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