Miscellaneous 2008

Tax case: Roche Products v Federal Commissioner of Taxation: Prices not profits

Source: Taxation In Australia Journal Article

Published Date: 1 Jun 2008

 
For some time, the application of the Australian transfer pricing rules has lacked certainty, especially in complicated cases, owing to the lack of any relevant Australian case law. A number of questions have remained unanswered, particularly the proper interaction of Australia’s domestic tax and treaty regimes. Resolving these questions affects the probity of the expert evidence upon which taxpayers rely when dealing with related offshore entities in circumstances giving rise to transfer pricing issues.
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Adam Russoniello

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