The Resource Intra-group loan financing and the arm's length principle : review of the Federal Court decision on Chevron Australia - Australia's recent large transfer pricing case

Intra-group loan financing and the arm's length principle : review of the Federal Court decision on Chevron Australia - Australia's recent large transfer pricing case

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Intra-group loan financing and the arm's length principle : review of the Federal Court decision on Chevron Australia - Australia's recent large transfer pricing case
Title
Intra-group loan financing and the arm's length principle : review of the Federal Court decision on Chevron Australia - Australia's recent large transfer pricing case
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Subject
Language
eng
Summary
The Chevron case (Chevron Australia Holdings Pty Ltd v Commissioner of Taxation (No 4) [2015] FCA 1092) deals with the interpretation of the arm's length principle in the context of inbound intra-group financing arrangements and the new (retrospectively applied) Australian transfer pricing provision (Subdivision 815-A). The case has been appealed and has important parallels to the famous Canadian GE Capital Inc. case as well as the new amendments to the OECD Transfer Pricing Guidelines implemented as a result of BEPS Actions 8-10, mainly with regard to topics such as risk, delineation of the actual transaction, and implicit support, and, to some extent, the importance of the rating approach in benchmarking loans
Citation source
In: TPI - Transfer Pricing International. - Wien. - Vol. 1 (2017), no. 1 ; p. 40-43
http://library.link/vocab/creatorName
Storck, A
Language note
English
http://library.link/vocab/subjectName
  • case law
  • transfer pricing
  • intra-group financing
  • arm's length principle
Label
Intra-group loan financing and the arm's length principle : review of the Federal Court decision on Chevron Australia - Australia's recent large transfer pricing case
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Publication
Label
Intra-group loan financing and the arm's length principle : review of the Federal Court decision on Chevron Australia - Australia's recent large transfer pricing case
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