Congruence and divergence in transfer pricing in Australia and Japan : intangibles and advance pricing agreements

Journal
Markham, M.
Australia
Asia-Pacific Tax Bulletin 2009 (Volume 15), No. 5
FormatPDF
EUR
40
| USD
45
(VAT excl.)

This article compares and contrasts the approaches taken by Australian and Japanese tax authorities in the areas of transfer pricing relating to intangibles and advance pricing agreements. The analysis is particularly interesting in light of the coming into force of the new Australia-Japan tax treaty on 3 December 2008.