‘Not at arm’s length’ - Federal Court sides with Commissioner in SingTel transfer pricing case

As discussed by Angelina Lagana, Keith Swan, Jeremy Capes, Sean Madden and Joseph Tranzillo, this case involved a financing arrangement between two related companies over a ten-year period which was subject to multiple amendments.

The Federal Court has handed down judgment in Singapore Telecom Australia Investments Pty Ltd v Commissioner of Taxation [2021] FCA 1597 (SingTel Decision), dismissing the taxpayer’s appeal and finding in favour of the Commissioner. The case involved a financing arrangement between two related companies over a 10-year period which was subject to multiple amendments. The case turned on those series of amendments made to the arrangement. The Commissioner succeeded in arguing that independent...

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Authors: Angelina Lagana, Keith Swan,

Published Date: 17 December 2021