Commentary

D1.8110 Contracts not at arm's length

Corporate tax
Corporate tax | Commentary

D1.8110 Contracts not at arm's length

Corporate tax | Commentary

Anti-avoidance provisions

D1.8110 Contracts not at arm's length

Transfer pricing

Where the transfer pricing provisions in TIOPA 2010, Pt 4 (ss 146–217) (see Division B4.1) apply to a derivative contract, an adjustment has to be made for any foreign exchange gains and losses in respect of the contract; the transfer pricing rules do not apply to exchange gains and losses.

If the transfer pricing rules require the computation to be made on the basis that the contract had not been made, any exchange gains or losses on that contract must also be left out of account1. For exchange movements arising

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