Australian Transfer Pricing Alert - Cross border related party financing arrangements are firmly within the ATO sights
23 May 2017
In April 2017, the Full Federal Court ruled against Chevron Australia Holdings Pty Ltd (Chevron Australia) in favour of the Australian Taxation Office (ATO) on appeal. The case was heard in relation to the transfer prices on intragroup financing between the overseas related party and the recipient of funds, Chevron Australia. This was the longest running transfer pricing legal case in Australia, and the ATO win is significant in the Australian, and possibly global, transfer pricing landscape. Given the significance of the win, this is definitely not the last intragroup financing case we will see the ATO challenge.