The increase in the use (or abuse) of international entities for tax avoidance and evasion, the increase in cross border trade and the birth of intangibles have given rise to a tightening of laws on transfer pricing. The Commissioner of Taxation in Australia asserts that most transactional transfer pricing methods are applicable in Australia. However, the EU has had issues in uniformly applying transactional methods and thus the idea of the Common Consolidated Corporate Tax Base - CCCTB - was born. This article compares the Australian and EU systems and gives a comprehensive overview of the CCCTB, its benefits and shortfalls, and some recommendations.
"The Arm’s Length Principle and the CCCTB: Solutions to transfer pricing issues for individual countries and the European Union?,"
Revenue Law Journal: Vol. 19
, Article 6.
Available at: http://epublications.bond.edu.au/rlj/vol19/iss1/6