Snf (Australia) Pty Ltd v Commissioner of Taxation
| Jurisdiction | Australia Federal only |
| Neutral Citation | 2010-0625 FCA D |
| Date | 2010 |
| Court | Federal Court |
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5 cases
- Secretary, Department of Sustainability and Environment (Vic) v Minister for Sustainability, Environment, Water, Population and Communities (Cth)
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Singapore Telecom Australia Investments Pty Ltd v Commissioner of Taxation
...or features which should be included. In SNF at first instance (SNF (Australia) Pty Ltd v Commissioner of Taxation (2010) 79 ATR 193; [2010] FCA 635) Middleton J observed at Just as in a valuation, the focus is not on the subjective or special factors of the parties involved in the transact......
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Commissioner of Taxation v Glencore Investment Pty Ltd
...Minister for Immigration and Border Protection v. SZVFW (2018) 264 C.L.R. 541 SNF (Australia) Pty Ltd v. Federal Commissioner of Taxation [2010] FCA 635; (2010) 79 A.T.R. 193 State Rail Authority of New South Wales v. Earthline Constructions Pty Ltd (in liq) [1999] HCA 3; (1999) 73 A.L.J.R.......
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Glencore Investment Pty Ltd v Commissioner of Taxation of the Commonwealth of Australia
...v SNF (Australia) Pty Ltd (2011) 193 FCR 149; [2011] FCAFC 74 SNF (Australia) Pty Ltd v Commissioner of Taxation (2010) 79 ATR 193; [2010] FCA 635 W R Carpenter Holdings Pty Ltd v Federal Commissioner of Taxation (2008) 237 CLR 198; [2008] HCA 33 Date of hearing: 5-7, 10-14, 17-19 December ......
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6 firm's commentaries
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Retrospective operation of Australias transfer pricing law reforms
...new law is applied to past matters previously subject to audit or dispute. Footnotes 1 SNF (Australia) Pty Ltd v Commissioner of Taxation [2010] FCA 635 2 Undershaft (No. 1) Ltd and Undershaft (No. 2) BV v Commissioner of Taxation [2009] FCA 41 3 Roche Products Pty Ltd v FC of T [2008] AATA......
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The OECD multilateral instrument has widespread tax implications
...[Chevron Australia Holdings Pty Ltd v Commissioner of Taxation [2015] FCA 1092 and SNF (Australia) Pty Ltd v Commissioner of Taxation [2010] FCA 635], it is unclear whether any real or useful lesson can be drawn from However, it is clear that the Convention, which will require significant w......
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MRRT: The Policy Transition Group's new issue paper
...useful guidance on market value calculation methodologies. However, we note that the SNF (Australia) Pty Ltd v Commissioner of Taxation [2010] FCA 635, a Federal Court case on appropriate market value methodologies in the transfer pricing context, has recently been appealed by the Commissio......
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Flexing Of The Arm's Length Principle In Australia: The Chevron Transfer Pricing Case
...by a profit-based pricing methodology may be a pragmatic way forward. Footnotes 1 SNF (Australia) Pty Ltd v Commissioner of Taxation [2010] FCA 635 2 Offshore marketing/trading hubs based in Singapore and Hong Kong are under close examination at the moment. This is due to the imposition of ......
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