A study of cross-border profit shifting channels

In this study, we investigate two cross-border profit shifting channels of foreign multinational enterprises (MNEs) in Australia and assess the...

The Chevron Australian Holdings Case and the reach of the arm's length principle

The recent decision by the Full Federal Court in Chevron Australia Holdings Pty Ltd v Commissioner of Taxation [2017] FCAFC 62 is a watershed, not only in...

Mind the gap - The arm's length principle and MNE value creation

Multinational enterprises (MNEs) operating by way of wholly owned subsidiaries are responsible for an increasing percentage of global trade. This paper...