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Expert Analysis

The Problem With Prediction In Transfer Pricing

By Matthew Frank (October 23, 2018, 3:22 PM EDT) -- In April 2017, the Federal Court of Australia decided the high profile case of Chevron Australia Holdings v. Commissioner,[1] ruling in favor of the commissioner and disallowing the equivalent of approximately $500 million in deductions for interest paid by an Australian borrower to its affiliated U.S. lender. The court found that the interest rate on the intercompany loan was too high under the arm's length standard....

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