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

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Abstract

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.
Original languageEnglish
Pages (from-to)308-320
Number of pages13
JournalAsia Pacific Tax Bulletin
Volume15
Issue number5
Publication statusPublished - 2009

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