Australia - Commissioner Loses Transfer Pricing Appeal in SNF Case
- M. Butler; J. Pengelly
- International Transfer Pricing Journal, 2011 (Volume 18), No 5
- 26 August 2011
The authors consider the recent decision of the Full Federal Court in the SNF case, which concerns the determination of arm's length consideration under a CUP analysis. The possible response of the Commissioner to his loss in this case is also discussed.