Title

Congruence and divergence in transfer pricing in Australia and Japan: Intangibles and advance pricing agreements

Date of this Version

10-1-2009

Document Type

Journal Article

Publication Details

Interim status: Citation only.

Markham, M. (2009). Congruence and divergence in transfer pricing in Australia and Japan: Intangibles and advance pricing agreements. Asia-Pacific tax bulletin, 15(5), 308-320.

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2009 HERDC submission. FoR code: 1801

© Copyright Michelle Markham, 2009

Abstract

This article compares and contrasts the approaches taken by Australian and Japanese tax authorities in the areas of transfer pricing relating to intangibles and advance pricing agreements. The analysis is particularly interesting in light of the coming into force of the new Australia--Japan tax treaty on 3 December 2008.

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