In this article, the authors explain the compromise approach developed by courts when setting transfer prices for transactions where there are no actual comparable arm’s length prices and illustrate the process with recent examples from Australia

As part of the Organisation for Economic Co-operation and Development's Base Erosion and Profit Shifting project, country-by-country reporting (CbCR) has been promoted as a mechanism to enhance transparency with respect to the operations and tax planning activities of large multinational...

In 2013 the OECD released its 15-point action plan to deal with base erosion and profit shifting (BEPS), which recognised that BEPS has a significant effect on developing countries because the lack of tax revenue can lead to a critical underfunding of public investment that would help promote...

This chapter examines the historical development of the formulary apportionment approach in key jurisdictions.From the time income taxes were first widely enacted, tax designers have been concerned with the question of how to allocate profits in transactions that incorporated labour, capital or...

Widely publicised profit-shifting cases in Europe against multinationals such as Starbucks, Fiat, Apple and Amazon have caught the attention of Australian scholars and tax officials with the revelation of the direct involvement of Australian subsidiaries such as Apple in the arrangements. The...

China attracted considerable foreign investment following the opening of its economy in 1979. With the switch to a quasi-market economy, China became reliant on taxes to fund government, opening the door to potential double taxation of profits from foreign investment, first in China and second...