Transfer pricing controversy – current key themes

This article explores three key themes currently being observed in transfer pricing controversy, as multinational taxpayers continue to grapple with ongoing developments.

It's no secret that it has been a busy time for transfer pricing controversy, as multinational taxpayers continue to grapple with ongoing developments from the courts, the Australian Taxation Office (ATO) and internationally. KPMG clients and partners gathered late last year in Sydney and then Melbourne for our inaugural Transfer Pricing Controversy (TPC) lunch with our special guests, former Justice Tony Pagone AM KC and Deputy Commissioner Fiona Knight. Justice Pagone is a former member o...

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Authors: Jeremy Capes, James Alsop,

Kristie Schubert
, Daniel McLindon

Published Date: 04 July 2025

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