Taxation Webcasts

Review of Australia's Transfer Pricing rules

In early November, the Australian Government released a consultative document announcing a review of Australia's transfer pricing rules, plus a separate and controversial amendment which would see Article 9 of Australia's Double Tax Agreements being applied as a taxing power in its own right. This amendment is described as a clarification of existing law rather than a change in law however many would dispute this claim.

The consultation process in relation to the consultative document has now closed, however, interested parties will have the opportunity to provide further comment and submissions when the draft legislation is released early in the new year.
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Interaction of thin capitalisation and transfer pricing provisions - webcast now available

After years of consultation, this webcast discusses the long-awaited release of transfer pricing Taxation Ruling TR 2010/7 which sets out the Australian Taxation Office's views on the contentious issue of the interaction of the thin capitalisation and transfer pricing provisions in the context of pricing related party debt.

Please join our expert Transfer Pricing and International Tax specialists during this webcast as they discuss the key focus issues of the Ruling, as well as the potential impact of the Ruling on intercompany financing within the Australian transfer pricing landscape.

Select the thumbnails to listen the audiocast.
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SNF Transfer Pricing Case

This audiocast discusses the recent Australian SNF case and the implications for multinationals with Australian business operations.

The SNF case concerned whether prices paid by an Australian distributor for products purchased from associated offshore manufacturing entities were arm's length. For 13 years the taxpayer had paid no tax and made trading losses in all years bar two. In a significant win for the taxpayer, the Australian Federal Court accepted the taxpayer's direct transactional evidence of arm's length prices and rejected the Commissioner of Taxation's application of a profit-based transfer pricing method.

In addition to discussing the legal aspects of the judgment, our Transfer Pricing and Tax Controversy specialists discuss the potential impact of the judgment on Australian transfer pricing administration.