Australian judge sets aside OECD guidelines
June 30, 2010
An Australian company has won an important decision in the Federal Court over use of the comparable uncontrolled price (CUP) method when a distributor purchases from associated offshore manufacturing entities.
Justice John Eric Middleton found in favour of the taxpayer in SNF (Australia) Pty Ltd v Commissioner of Taxation, a case in which also stepped back from the OECD rules in making his judgement.
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