Transfer pricing Miscellaneous 2017

Hypothesising the future after Chevron

Source: Taxation In Australia Journal Article

Published Date: 1 Jun 2017


This article summarises the much-anticipated judgment of Chevron Australia Holdings Pty Ltd v FCT. In a landmark win for the ATO, the Full Federal Court unanimously dismissed Chevron's appeal, making it one of Australia's largest tax cases, with global implications for large companies and multinationals. With a tax bill totalling $340m, a special leave application has been filed by Chevron. This case provides the foundation for multinational entities to examine their own internal financing arrangements. However, with the changes to Australia's transfer pricing rules in 2013, significant changes have been enacted to the way in which the transfer pricing regime is invoked and the operation of the arm's length principle. The utility of Chevron must be considered in light of these legislative changes.

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Transfer pricing Miscellaneous 2017

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