Commissioner Loses Transfer Pricing Appeal in SNF Case

Journal
Butler, M.; Pengelly, J.
Australia
International Transfer Pricing Journal 2011 (Volume 18), No. 5
FormatPDF
USD
50

The authors consider the recent decision of the Full Federal Court in the SNF case, which concerns the determination of arm's length consideration under a CUP analysis. The possible response of the Commissioner to his loss in this case is also discussed.