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Transfer pricing – is there an “internationally accepted arm’s length principle”?

Published on 01 Jun 09 by "THE TAX SPECIALIST" JOURNAL ARTICLE

The issue before the High Court in the Carpenter litigation was the entitlement of the taxpayer to particulars of the matters taken into account by the Commissioner in making a determination under Div 13. This paper considers that issue and issues relating to the application of Div 13 to cross-border interest free financial accommodation.

Author profile:

James Momsen
James is a Barrister, Selborne Chambers. Current at 01 June 2009 Click here to expand/collapse more articles by James H MOMSEN.
 
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