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The Glencore decision is a landmark decision on the application of Australia’s transfer pricing rules governing transactions within multinational groups. These rules seek to ensure that tax is not avoided as a result of non-arm’s length related party dealings.

Following the High Court of Australia’s decision to not grant special leave to appeal the decision, Of Counsel Benjamin Lancaster explores its implications for taxpayers undertaking transactions that are subject to the current transfer pricing laws in Australia and around the world.