Abstract
[Extract]
Historically, the number of tax treaty disputes experienced by Australia has been relatively low. The latest OECD mutual agreement procedure (MAP) statistics for 2016 reveal that in relation to Australia, for cases which started before 1 January 2016, the starting inventory included 23 transfer pricing cases and 9 other cases, with an ending inventory of 16 transfer pricing cases and 7 other cases.2 During the 2016 calendar year, 12 transfer pricing MAP cases and 10 other MAP cases were started in relation to Australia, with one of these transfer pricing cases and two of the other cases being closed by 31 December 2016, resulting in a total of 27 transfer pricing cases and 15 other cases in the ending inventory at this date.
Historically, the number of tax treaty disputes experienced by Australia has been relatively low. The latest OECD mutual agreement procedure (MAP) statistics for 2016 reveal that in relation to Australia, for cases which started before 1 January 2016, the starting inventory included 23 transfer pricing cases and 9 other cases, with an ending inventory of 16 transfer pricing cases and 7 other cases.2 During the 2016 calendar year, 12 transfer pricing MAP cases and 10 other MAP cases were started in relation to Australia, with one of these transfer pricing cases and two of the other cases being closed by 31 December 2016, resulting in a total of 27 transfer pricing cases and 15 other cases in the ending inventory at this date.
Original language | English |
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Title of host publication | Tax Treaty Arbitration |
Editors | Michael Lang, Jeffrey Owens, Pasquale Pistone, Alexander Rust, Josef Schuch, Claus Staringer, Alfred Storck |
Publisher | IBFD Publications |
Chapter | 2 |
Pages | 37-62 |
Number of pages | 26 |
ISBN (Electronic) | 978-90-8722-615-2, 978-90-8722-616-9 |
ISBN (Print) | 978-90-8722-614-5 |
Publication status | Published - Apr 2020 |
Publication series
Name | WU Institute for Austrian and International Tax Law - Tax Law and Policy Series |
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Volume | 15 |
ISSN (Electronic) | 2451-8360 |