Tag Archives: commercial sense

After the decisions in Roche and SNF (on appeal) the next big thing to jolt the transfer pricing world in Australia was the release of the much anticipated ruling TR 2011/1 this week. This ruling prescribes the steps that need to be taken when undertaking business restructuring, so that one does not get pitted against the tax office. The most significant aspect of the ruling is the ‘commercial sense’ requirement in order to conform with the transfer pricing rules and … Continue reading →