2020

2020 National Transfer Pricing Online Part 4 - Litigation: Glencore case and ATO's appeal

Source: National

Published Date: 17 Sep 2020

 
After its resounding victory in Chevron, the ATO's resounding loss at first instance in Glencore has re-focussed attention on the legal and practical difficulties of applying Australia's transfer pricing laws. With the ATO's appeal scheduled to be heard in August, this session reminded attendees of the complex facts and issues in the case and critically examine the competing positions of the parties on appeal with reference to the case's potential wider implications.

Topics included: reconciling Chevron with Glencore, the concept of comparability, the concept of reconstruction, and the relationship between conditions and commercial and financial relations. These were discussed with reference to the legislation and the policy underpinning it, as well as what the appeal might mean in practice for transfer pricing practitioners.

Details

  • Published On:17 Sep 2020
  • Took place at:Online

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Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

This material is copyright. Apart from any fair dealing for the purpose of private study., research, critisism or review, as permitted under teh copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.

Unless expressly stated, opininons are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

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