Congruence and divergence in transfer pricing in Australia and Japan : intangibles and advance pricing agreements
Journal
Country
Australia
Published Date
Issue
Asia-Pacific Tax Bulletin 2009 (Volume 15), No. 5
Document
This article compares and contrasts the approaches taken by Australian and Japanese tax authorities in the areas of transfer pricing relating to intangibles and advance pricing agreements. The analysis is particularly interesting in light of the coming into force of the new Australia-Japan tax treaty on 3 December 2008.