Why SNF won comparables litigation in Australia
December 16, 2011
Sophie Ashley - TPW
The Australian Tax Office (ATO) has lost its appeal against the taxpayer, SNF, at the Full Federal Court in a transfer pricing case concerning comparables and method application.
In a unanimous decision, the court described the ATO’s arguments as “simply illogical” which could lead to “impractical outcomes”.
The decision shows taxpayers that the tax authorities’ approach to transfer pricing may not be as supportable by law as it would to have them believe.
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