Australia vs PEPSICO: TRANSFER PRICING CASE
This case, decided by the Federal Court of Australia on 30 November 2023, addressed key taxation issues involving royalty withholding tax and diverted…
Category: Oceania
Australia vs Oracle: Transfer Pricing Case
This case addressed Oracle Corporation Australia Pty Ltd’s application to temporarily stay domestic court proceedings while a Mutual Agreement Proce…
Australia vs SNF: In-Depth Summary
The case Commissioner of Taxation v. SNF (Australia) Pty Ltd concerned a dispute over the application of the arm's length principle in the context of …
Australia vs SingTel Transfer Pricing Case
The High Court of Australia deliberated on a significant transfer pricing case between Singapore Telecom Australia Investments Pty Ltd (STAI) and the …
PepsiCo v Australia: Implications for Royalty Withholding Tax and Diverted Profits Tax
The Federal Court of Australia's judgment in PepsiCo, Inc v Commissioner of Taxation provides critical insights into the characterization of payments …
Case Analysis: Mylan Australia Holding Pty Ltd v Commissioner of Taxation
Detailed analysis of the Federal Court of Australia’s judgment in Mylan Australia Holding Pty Ltd v Commissioner of Taxation [2024] FCA 253, focusin…
Transfer Pricing Dispute Between Australia and Glencore Investment Pty Ltd
Glencore Australia (CMPL) sold copper concentrate produced in Australia to its Swiss parent, Glencore International AG (GIAG).
The tax authorities …
Timeless principles of taxpayer protection: how they adapt to digital disruption
Paper by: Duncan Bentley This article analyses the impact of digitalisation on the tax administrationTax authorities are fundamental institutions within government frameworks, overseeing tax assessmentA tax assessment is a formal determination made by a tax authority to calculate the amount of tax an individual or entity owes. It is a comprehensive evaluation based on financial records, declared income, expenses, deductions, and any applicable tax laws or regulations. Tax assessments may arise from routine self-assessments by taxpayers, or they may be conducted by revenue authorities...,
International Taxation of E-commerce Business Income
Article by: Dr. Dennis Ndonga (Lecturer, Murdoch University Australia) The rapid growth of cross-border e-commerce has challenged the existing international tax principles that are structured
Double Tax Treaties: An Introduction
Paper by: Reuven S. Avi-Yonah The existing network of over 2,500 bilateral double tax treaties (DTTs) represents an important part of international law. The current