Profit shifting

Working paper

The Glencore Case: transfer pricing and the world of possibilities

The important and contentious Glencore Case breaks new ground in the application of Australia’s transfer pricing rules to an integrated global business, particularly in framing how the rules take into account business and market risks impacting on such a business.
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...