The role of economic analysis in resolving uncertainties in the source concept and the arm's length principle

The 2015 OECD review of its transfer pricing guidance was in part focussed on the need to align transfer pricing outcomes with value creation, a process...

Transfer pricing: The Glencore appeal. To hedge or not to hedge? That is the question

The Full Federal Court decision in the Glencore Case raises very important questions in relation to core concepts underlying Australia’s previous and...

The Glencore Case: Transfer pricing and the world of possibilities

The important and contentious Glencore Case breaks new ground in the application of Australia’s transfer pricing rules to an integrated global business,...