Alcoa successful in transfer pricing dispute over sales of alumina

Key to the Administrative Review Tribunal case was the wide range of different contractual and pricing mechanisms used in the market, as highlighted by Sam van Berkel, Glen Hutchings, Kristie Schubert, Jeremy Capes and James Alsop.

The Administrative Review Tribunal (Tribunal), on 30 April 2025, published its decision in Alcoa of Australia Ltd and Commissioner of Taxation (Taxation and business) [2025] ARTA 482 (the Alcoa case). The Alcoa case involved the application of Australia's prior transfer pricing regime in Division 13 of the Income Tax Assessment Act 1936 to certain sales of alumina shipped to a third-party Bahrain smelter between 1993 and 2009. Although the case was determined on the basis of demonstrating t...

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Authors: Sam van Berkel, Glen Hutchings,

Published Date: 06 May 2025