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Recent trends in transfer pricing litigation in Australia paper

Published on 14 Sep 11 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This paper covers:

  • the SNF decision
  • evidentiary challenges
  • attempts to stem the tide of losses
  • evidence of a global market
  • OECD guidelines
  • Roche Australia v the Commissioner of Taxation
  • relevant facts
  • expert reports
  • appropriate choice of comparables
  • contract between RB and Bayer AG ("Inhibace")
  • choice of OECD methodology.

Author profiles:

Peter Callejah

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Paul MCNAB

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Colin Little

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This was presented at International Masterclass .

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