Undershaft (No 1) Ltd v Commissioner of Taxation
| Jurisdiction | Australia Federal only |
| Neutral Citation | 2009-0203 FCA B |
| Date | 2009 |
| Year | 2009 |
| Court | Federal Court |
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3 firm's commentaries
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Retrospective operation of Australias transfer pricing law reforms
...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 639 4 Polyukovich v The Commonwealth [1991] HCA 32 The content of this article is intended to provide ......
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The OECD multilateral instrument has widespread tax implications
...agreement) eg Virgin Holdings SA v Commissioner of Taxation [2008] FCA 1503; Undershaft (No 1) Limited v Commissioner of Taxation [2009] FCA 41. Article 3 of the Convention modifies the operation of covered tax agreements (DTAs) and provides for rules to reduce the incidence of hybrid doubl......
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Australian Tax Update: Interaction of Australia's transfer pricing, thin capitalisation rules and double tax treaties
...in addition to that provided by the thin capitalisation rules. Most importantly in Undershaft (No 1) Limited v Commissioner of Taxation [2009] FCA 41 (Undershaft (No. 1) Case), Justice Lindgren in several directly targeted comments stated that the principal purpose of Double Tax Treaties wa......