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.