Transfer pricing


Working paper

Transfer pricing: the Glencore appeal. To hedge or not to hedge? That is the question

This paper argues that there are important questions of law that arise from the Glencore Case appeal decision that would warrant the seeking of special leave to appeal to the High Court.
Working paper

The Chevron Australian Holdings case and the reach of the arm's length principle

The recent decision by the Full Federal Court in Chevron Australia Holdings Pty Ltd v Commissioner of Taxation [2017] FCAFC 62 is a watershed, not only in Australia but internationally. It provides important insights into how the arm’s length principle takes account of the economic...
Working paper

Mind the gap - The arm's length principle and MNE value creation

Multinational enterprises (MNEs) operating by way of wholly owned subsidiaries are responsible for an increasing percentage of global trade. This paper looks at how the existing rules based on the arm’s length principle allocate a MNE’s profit between the taxing jurisdictions in which it operates...