Ato Warns: No Tax Return, No Payments; How We Will All Get PaidByline: Peter Chapman peter.chapman@dailyexaminer.com.auDaily Examiner (Grafton, Australia)
The transfer pricing benefit must be assessed and negated for each tax year, not on a hindsight basis over the total loan period. The determination of arm’s length profits, and any “excessive” interest deductions, had to occur year by year. This was fundamental to how the tran...
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On December 17, the Federal Court of Appeals ruled in favor of the Australian Tax Office (ATO) inSingapore Telecom Australia Investments Pty Ltd v. Commissioner of Taxation. The issue involved what the ATO suggested was intercompany interest payments in excess of the arm’s length standard. Bac...