Transfer pricing Miscellaneous 2014

Transfer pricing and the quest for the Golden Fleece

Source: Taxation In Australia Journal Article

Published Date: 1 Oct 2014


Tax base erosion as a result of technologically-driven economic globalisation has emerged as a severe threat to national economies. The threat has given rise to the OECD’s Action plan on base erosion and profit shifting, and a new tax concept, to the effect that profits should be taxed where the “real activity” that generates them is occurring. In Australia, it is a common complaint that certain multinational corporations are shifting or otherwise transferring untaxed profits from their Australian operations to various entity structures in competitive tax regimes.

This article examines the validity of that complaint, in the light of the phenomenon of economic globalisation and its effects on transfer pricing rules and the traditional concepts of source and residence as the criteria of taxation liability

Sorry, this is subscriber only content.

To gain access to this material and much more - Subscribe Now.

(Note: Members can access Taxation in Australia journal articles without a Tax Knowledge Exchange subscription - please log in to access).

Already a Subscriber? Login now


The material is copyright. Apart any fair dealing for the purpose of private study, research criticism or review, as permitted under the copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.

Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

The Tax Institute
(ABN 45 008 392 372 (PRV14016))


The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009. 

Copyright Statement

All materials provided on this site are protected by copyright and are owned by or licensed to TTI.

Except as expressly permitted by TTI or the copyright owner, any person or company who uses this site must not use, reproduce, redistribute, retransmit, publish or otherwise transfer, or commercially exploit, the materials or any information, software or other content, in whole or in part, which is available through this site.


Transfer pricing Miscellaneous 2014

Share this page