Source: Taxation In Australia Journal Article
Published Date: 1 Feb 2021
The decision of the Full Federal Court in FCT v Glencore Investment Pty Ltd reinforces the importance of facts and evidence, including lay and expert witnesses, for both taxpayers and the Commissioner in transfer pricing cases. The opportunity for the Commissioner to reconstruct international agreements to support transfer pricing adjustments appears to have been narrowed. However, it will be necessary to see how far that extends to transactions to which Subdiv 815-B ITAA97 could apply. The reduced reliance on the OECD guidelines is also of interest. A clear message is that transfer pricing is not an exact science and that there
will not generally be one perfect price. Rather, there will be an acceptable range. Regardless, the need for taxpayers to document and validate their positions remains unchanged and cannot be overstated.
Why corporates should engage with tax corporate governance - Presentation 26 May 2022
Why corporates should engage with tax corporate governance - Video 26 May 2022
Why corporates should engage with tax corporate governance - Paper 26 May 2022
High wealth private groups: Risk reviews - Journal 01 Apr 2021
COVID-19 stimulus package webinar part 7: Advising in an environment of rapid change - Audio 21 May 2020
Identifying and managing Covid-19 risks and dispute pressure points - Presentation 21 May 2020
COVID-19 stimulus package webinar part 7: Advising in an environment of rapid change - Video 21 May 2020
Mind the gap - the Placer Dome decision - Paper 25 Jul 2019
Mind the gap - The Placer Dome decision - Presentation 25 Jul 2019
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.
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.