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Articles

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Glencore Transfer Pricing Decision

Australia, OECD - September 17 2019 The Australian Taxation Office (ATO) has been arguing that Australia’s transfer pricing rules include a broad power to reconstruct transactions with...

Graeme Cooper, Cameron Blackwood, David Bond.

New corporate residence rules?

Australia - August 29 2019 The residence of corporate entities has not been an especially contentious part of Australian tax law. If the entity was classified as a non-resident...

Graeme Cooper, Cameron Blackwood.

2019 International Dealings Schedule changes for Financial Services

USA, Australia - July 18 2019 The ATO has released the 2019 version of the International Dealings Schedule (IDS) and there have been significant changes compared to previous years...

Andrew Hirst, Mary Hu.

Staples Legislation - ATO releases Draft Law Companion Ruling

Australia - June 26 2019 With three business days before 30 June 2019, being the last day for entities subject to a cross staple arrangement to make a choice that...

Aldrin De Zilva, Nicholas Rouse, Chris Colley, Ryan Leslie.

Arm’s length debt test - ATO issues draft tax ruling

Australia - April 17 2019 On 5 April 2019, the Australian Taxation Office (ATO) released draft Taxation Ruling (TR) 2019D2 providing updated guidance on the “arm length debt...

David Bond.