transfer pricing

August 8, 2017

Transfer pricing: interest rate on borrowing not arm’s length

In a major transfer pricing judgment (“the Chevron Case”), the Full Federal Court has unanimously dismissed Chevron Australia’s appeal, finding that its loan arrangement with its related US company, Chevron Texaco Funding Corporation, was not at arm’s length and the Commissioner was justified in denying Chevron Australia’s interest deduction claims. At the crux of the…