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Tag Archives: Roche
Transfer pricing- Guidelines (OECD) are just that
The Full Federal Court has rejected the Commissioner’s appeal in the case of FC of T v SNF (Australia) Pty Ltd [2011] FCAFC 74 (1 June 2011). Interestingly the court also rejected the argument that the relevant double tax treaty, especially Article 9 (Associated Enterprises) applied in the interpretation of sections 136AA and 136 AD (determination of arm’s length consideration). This is contrary to the position taken in the decision impact statement of Roche Products Pty Ltd v Commissioner of … Continue reading
Transfer pricing – all foam and no beer
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
