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Australia vs SNF: JUDGMENT

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Australia vs SNF: JUDGMENT

Case Information

  • Court: Full Federal Court of Australia
  • Case No: 2011 ATC 20-265
  • Applicant: Commissioner of Taxation
  • Defendant: SNF (Australia) Pty Ltd
  • Judgment Date: 1 June 2011

The case Commissioner of Taxation v. SNF (Australia) Pty Ltd concerned a dispute over the application of the arm’s length principle in the context of transfer pricing regulations under Australia’s Income Tax Assessment Act 1936 (ITAA 1936). SNF, a subsidiary of the French-based multinational SNF Group, had imported chemicals—primarily polyacrylamides—from related foreign suppliers in France, the United States, and China. The Commissioner challenged the pricing of these imports, arguing that SNF Australia had paid its related suppliers more than an independent buyer would under comparable circumstances. Consequently, the Commissioner assessed additional income tax on SNF, claiming that the prices paid exceeded the arm’s length amounts required under Section 136AD(3) of the ITAA 1936.

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Categories: Australia
Tags: ALP, Arms Length Principle, Comparable Uncontrolled Price Method, CUP, Global Tax, Tax Compliance, Tax Law, Tax Risk Management, TNMM, Transactional Net Margin Method, Transfer Pricing
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Dimension Transfer Pricing International Taxation South African Tax Law
Jurisdictional audience Global audience, covers all jurisdictions Global audience, covers all jurisdictions South Africa specific, relevant to SADC region
Ideal for TP managers, advisors, in-house tax teams, analysts moving into TP Advisors and managers dealing with cross-border rules, treaties, planning Practitioners working with the SA Income Tax Act, cases, compliance
Core focus Methods, comparables, DEMPE, documentation, audits, dispute defence Treaties, source vs residence, anti-avoidance, PE, relief from double tax Statutory interpretation, case law, assessments, objections, local practice
Primary tools OECD TP Guidelines, UN Manual, BEPS Actions 8–10, 13, case law OECD and UN Models, MLI, BEPS 1.0 and 2.0, domestic rules, cases Income Tax Act, SARS practice notes, Tax Administration Act, SA cases
Assessment style Case-based assignments, file reviews, short written defences Problem questions, treaty interpretation, position papers Problem questions, statutory analysis, case commentary
Typical outcomes Build defensible TP files and strategies, improve audit readiness Design cross-border structures within rules, mitigate double tax Apply SA tax law accurately, manage reviews and disputes
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Dimension Conducting a Transfer Pricing Trial Effectively Managing Tax Teams Indirect Taxation Tax Risk Management
Jurisdictional audience Global audience Global audience Global audience, with local adaptation Global audience
Ideal for In-house tax, TP managers, litigators, advisors preparing for audits, ADR, trial Heads of tax, managers, team leads, controllers, emerging leaders VAT, GST, customs, finance managers, AP, AR, compliance specialists Tax managers, risk officers, controllers, advisors building governance
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Delivery mode Online, live sessions plus guided self-study Online, live sessions plus guided self-study Online, live sessions plus guided self-study Online, live sessions plus guided self-study
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Assessment End of module progress assessment

5000-word assignment if PG-Cert option elected		 End of module progress assessment

5000-word assignment if PG-Cert option elected		 End of module progress assessment

5000-word assignment if PG-Cert option elected		 End of module progress assessment

5000-word assignment if PG-Cert option elected