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Full Federal Court dismisses Commissioner’s appeal in landmark transfer pricing decision
Consideration of decision of Full Federal Court of Australia in Commissioner of Taxation v SNF (Australia) Pty Ltd [2011] FCAFC 74 on substantive transfer pricing issue.
Australia
13 Jul 2011
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Transfer Pricing: Taxpayer wins first Substantive Transfer Pricing Case in Australia.
The decision in SNF (Australia) Pty Ltd v. Commissioner of Taxation [2010] FCA 635 is good news for Australian businesses with international operations. It is the first Federal Court decision handed down on substantive transfer pricing issues. However, the case highlights the Tax Office’s hard-line approach to transfer pricing. The case also demonstrates the Tax Office’s preference to use the statistics-driven "transactional net margin method" (TNMM) to establish prices between international
Australia
13 Jul 2010
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