Australia - Guidance Regarding Reconstruction of Cross-Border Transactions by the Commissioner
- A. Joseph
- International Transfer Pricing Journal, 2015 (Volume 22), No 2
- 5 February 2015
This article considers subdivision 815-B of the Income Tax Assessment Act, which was introduced in 2013, as well as Taxation Ruling TR 2014/16 on the determination of substance in cross-border transactions.