Casenote - Swiss Pharma Company subject to transfer pricing adjustment

Journal
Author
Butler, M.St.J.R.
Country
Australia
Published Date
Issue
Asia-Pacific Tax Bulletin 2008 (Volume 14), No. 3
FormatPDF
EUR
45
| USD
50 (VAT excl.)

The Administrative Appeals Tribunal's (AAT) first decision on transfer pricing, resulting in an upward adjustment of the gross profit margin of a Swiss pharmacy group's Australian subsidiary is expected to have significant implications for multinational groups operating in Australia. This casenote (Roche Products Pty Ltd) examines the Australian transfer pricing rules and the manner in which expert evidence was evaluated by the AAT to arrive at the above conclusion.