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Unpacking the Alcoa transfer pricing case – 23 June 2025

 

On 30 April 2025, the new Administrative Review Tribunal handed down its decision on a transfer pricing case between the Commissioner of Taxation and Alcoa of Australia Ltd. The case focuses on historical transactions between Alcoa and an intermediary regarding the supply of alumina to a major customer in Bahrain over a period that predates Australia’s current transfer pricing rules. 

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