The KPMG member firm in Australia has provided analysis on the recent decision by the Full Federal Court in favour of the Commission of Taxation.
The decision in Chevron Australia Holdings Pty Ltd (CAHPL) v. Commissioner of Taxation  FCAFC 62 (21 April 2017), has implications not only for taxpayers with cross-border related-party financial dealings but also for taxpayers with any other cross-border related-party dealings.
The KPMG analysis [PDF 333 KB] provides insights into the approach that both courts and the Commissioner of Taxation are likely to take when examining transfer pricing issues going forward.
For more information, contact a tax professional in Australia with KPMG’s Global Transfer Pricing Services group:
Angela Wood | +61 3 9288 6408 | firstname.lastname@example.org
Frank Putrino | +61 3 9838 4269 | email@example.com
© 2017 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved.
The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.