Roche Products Case: Increasing Role of Transfer Pricing
- A. Joseph
- International Transfer Pricing Journal, 2009 (Volume 16), No 4
- 1 July 2009
In Australia, there had not been many judicial challenges to revenue determinations of arm’s length considerations until the case of Roche Products Pty Ltd v. Commissioner of Taxation, which was heard by the Administrative Appeals Tribunal in the middle of 2008. The author considers this significant case, along with the relationship between Australian income tax treaties, domestic law and OECD principles.