TaxTalk Alerts

Keeping you abreast of key tax developments as they occur throughout the month

Outlining the major business implications, our Alerts will ensure you are kept informed and help you respond accordingly. Browse through our Alerts below.

Taxpayer wins in High Court special leave proceedings to resolve the meaning of "permanent place of abode"

Recently, the High Court of Australia dismissed the Commissioner of Taxation’s application for special leave to appeal against the decision of the Full Federal Court which had found that the taxpayer, Mr Harding, was not a resident of Australia.

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Federal Court overturns ATO positions on transfer pricing 

The Federal Court recently handed down its decision in Glencore Investment Pty Ltd v Commissioner of Taxation of the Commonwealth of Australia in favour of the taxpayer, providing clarity in relation to Australia’s transfer pricing rules and, in particular, aspects of the Full Federal Court’s 2017 decision in the Chevron case.  

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PCG 2019/D3 - A way forward on the Arm's Length Test

The Australian Taxation Office (ATO) recently released draft Practical Compliance Guideline PCG 2019/D3, which sets out the ATO’s views on practical aspects of the Arm’s Length Debt Test which is relevant for thin capitalisation purposes.  

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