Abstract
The author considers Taxation Ruling TR 2011/1, which deals with the application of transfer pricing provisions to business restructurings of multinational enterprises where cross-jurisdictional transfers of functions, assets and risks of businesses occur. In this Ruling, the Australian Taxation Office reiterates its long-held position that Div. 13 of the Income Tax Assessment Act 1936 and Art. 9 (associated enterprises) of Australian income tax treaties are both based on the arm’s length principle, so there should be no fundamental inconsistency in the outcomes under the two sets of provisions.
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