Australia: IBM loses royalties transfer pricing case

ATO triumphs over IBM in $55m tax war – ZDnet – IBM were trying to extend the scope of a “private ruling”, which seems to be an advance pricing agreement of some sort on the transfer pricing of royalties.  The agreement was reached for 2004 and IBM considered that it should continue to apply after 2004, and also tried to get a refund for tax paid from 1987-2002 on that basis that the agreement should have retrospective effect.

The Australian Tax Office disagreed, and the court has upheld the additional tax  bill for 2005 onwards.

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