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Roche ruling marks first Australian transfer pricing case settled in court

April 07, 2008

David Stavropoulos and Andrew Spalding, of Deacons law firm, say that the ruling illustrates Tax Office policy on future adjustments

Historically, transfer pricing disputes between the Australian Taxation Office and taxpayers have been settled out-of-court. This decision is significant both because it is the first time that the transfer pricing provisions have been considered by a court or tribunal and because of the novel decision-making approach adopted by the Administrative Appeals Tribunal (AAT).

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