ATO produces guidance on Roche Products case
February 11, 2009
Tax professionals in Australia agree with the authorities’ view of the value of the Administrative Appeals Tribunal’s judgement in the Roche Products case, though some would have preferred a more comprehensive ruling from the AAT
Justice Downes, the president of the AAT, ruled last year, in an appeal by the taxpayer, that transfer pricing adjustments against Roche, a pharmaceuticals group, by the Australian Taxation Office (ATO) should be reduced from about A$126 million ($82.3 million) to about A$45 million ($29.4 million). He decided that the ATO commissioner’s assessments of how much income tax Roche in Australia should pay based on related-party transactions with other group companies, including its parent in Switzerland, were excessive.
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