Australia: Taxpayer withdraws appeal; transfer prices | KPMG Global
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Australia: Taxpayer withdraws appeal; transfer prices and related-party loans

Australia: Taxpayer withdraws appeal; transfer prices

A taxpayer has decided to withdraw its appeal to the High Court concerning an assessment by the Australian Taxation Office (ATO) of AUS $340 million in tax and penalties for interest payments made to related offshore parties.


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The taxpayer challenged Australia’s transfer pricing rules and the appropriate method for establishing an arm’s length interest rate for related-party loans. The case—Chevron Australia Holdings Pty Ltd v. Commissioner of Taxation—also raised constitutional issues regarding transfer pricing provisions. The Full Federal Court upheld the ATO’s position in April 2017. Read TaxNewsFlash-Transfer Pricing

The withdrawal of the appeal means that the April 2017 decision of the Full Federal Court is now final. Read a release (August 2017) issued from Australia’s Minister for Revenue and Financial Services.

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