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Insights for transfer pricing litigation


This article provides some insights in relation to preparing transfer pricing matters for litigation in the Federal Court or Administrative Appeals Tribunal. The article addresses topics including choice of forum, gathering documents, preparation of lay and expert evidence, as well as steps that may facilitate settlement. The authors seek to provide practical steps for ensuring that evidence is prepared in a targeted manner that addresses the real issues in dispute and that achieves the relevant forensic purpose. The article also considers possible future directions for transfer pricing litigation, including industries that may be the subject of future cases, as well as the kinds of legal questions that may fall to be determined.

Author profiles

Tamara Phillips
Tamara is briefed in a wide range of commercial and public law matters, with a focus on revenue law including international tax, local government/environmental law and judicial review. She regularly acts for and against major corporations, Commonwealth and State agencies and regulatory bodies. She has appeared in the High Court, Federal Court, NSW Court of Appeal, NSW Supreme Court and in tribunals and inquiries. In addition to advocacy work, Tamara’s practice involves opinion and advisory work for both private and government clients. - Current at 29 October 2019
Michael Cosgrove
Michael is a Barrister, New Chambers. - Current at 29 October 2019


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