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Daniel McInerney SC
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Commissioner of Taxation v Glencore – The Full Court decision
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Commissioner of Taxation v Glencore – The Full Court decision
The Full Federal Court’s recent decision in Commissioner of Taxation v Glencore Investment Pty Ltd v [2020] FCAFC 187 provides crucial guidance on the operation of the Australian transfer pricing regimes, including with respect to the arm’s length principle, the restructuring of transactions and the nature of the evidence relevant to the application of the transfer pricing provisions.
In this session, the panel will consider the implications arising from this important decision.