Published on 01 Jun 08
by "TAXATION IN AUSTRALIA" JOURNAL ARTICLE
For some time, the application of the Australian transfer pricing rules has lacked certainty, especially in complicated cases, owing to the lack of any relevant Australian case law. A number of questions have remained unanswered, particularly the proper interaction of Australia’s domestic tax and treaty regimes. Resolving these questions affects the probity of the expert evidence upon which taxpayers rely when dealing with related offshore entities in circumstances giving rise to transfer pricing issues.