Chevron Australia Holdings Judgment

Provides critically important guidance on both the 'old' and 'new' transfer pricing laws in Australia

By:
The Chevron decision provides critically important guidance on both the 'old' (Division 13) and 'new' (Subdivision 815-A) transfer pricing laws in Australia.  While not dealing specifically with Subdivisions 815-B to D, the decision is highly relevant to the deductibility of interest on all cross border financing arrangements and deals with several key related issues including thin capitalisation, double tax treaties, penalties, constitutional and procedural issues.