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Hypothesising the future after Chevron

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Published on 01 Jun 17 by "TAXATION IN AUSTRALIA" JOURNAL ARTICLE

This article summarises the much-anticipated judgment of Chevron Australia Holdings Pty Ltd v FCT. In a landmark win for the ATO, the Full Federal Court unanimously dismissed Chevron’s appeal, making it one of Australia’s largest tax cases, with global implications for large companies and multinationals. With a tax bill totalling $340m, a special leave application has been filed by Chevron. This case provides the foundation for multinational entities to examine their own internal financing arrangements. However, with the changes to Australia’s transfer pricing rules in 2013, significant changes have been enacted to the way in which the transfer pricing regime is invoked and the operation of the arm’s length principle. The utility of Chevron must be considered in light of these legislative changes.

Author profiles

Elizabeth Bishop FTI
Elizabeth is a Barrister who advises and represents resident and non-resident clients, high wealth individuals, private groups, corporates, revenue authorities and Federal and State government bodies in the AAT, NCAT, NSW Supreme Court, Federal Court and High Court of Australia. She has developed a practice predominantly in matters concerning land tax, payroll tax, stamp duty, income tax, goods and services tax, capital gains tax and tax fraud. - Current at 26 June 2019
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Scott Richardson
Scott is a barrister at Ground Floor Wentworth Chambers

 

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