Australia’s AAT hands down final decision in Roche ruling
July 30, 2008
Stuart Edwards of PricewaterhouseCoopers, Australia, believes courts will favour traditional transactional transfer pricing methods rather than bottom line profits methods in the wake of the landmark Roche decision.
On July 22 2008, Justice Downes, president of the administrative appeals tribunal (AAT), handed down his final decision in the transfer pricing case Roche Products Pty Ltd vs the Commissioner of Taxation [2008] AATA 639. In the final decision, the adjusted assessments totalled A$42.55 million ($40.3 million) ((as compared to the earlier preliminary decision of A$58.74 million ($55.6 million)). The reduced amount of the adjustments to assessable income arise from recalculations of gross profits across several years, including some increases, leading to amendments to the preliminary adjustments and one year where the time limit for amendment had passed and hence no adjustment was possible.
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