Australian Transfer Pricing Alert - What bearing does the Chevron decision have on Australia and the globe?
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 in relation to the transfer prices on intragroup funding between the overseas related party (the lender) and the recipient of funds, Chevron Australia (the taxpayer/ borrower). 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.