Source: The Tax Specialist Journal Article
Published Date: 1 Jun 2021
Australia's transfer pricing framework requires taxpayers, the courts and the Commissioner to consider three different legislative provisions depending on the year in question, any applicable double tax agreements, plus lengthy OECD commentaries and guidelines. This article explains the background to this framework and analyses judicial interpretations of it, with a particular focus on the four cases since 2008 to have dealt with the pricing of transactions challenged by the Commissioner under transfer pricing provisions. The article concludes that, in practice, the outcome under the three different legislative provisions may rarely, if ever, differ.
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