The Australian Tax Office has challenged the transfer pricing practices of BHP Billiton, serving the country’s largest taxpayer with a A$522 million ($432 million) tax bill, based on the pricing of goods it sold to a marketing affiliate in Singapore. The company’s Singapore tax bill is also being questioned under Australia’s controlled foreign company (CFC) rules, which require a minimum payment of tax.
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India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist
ITR sat down for a pre-event interview with Tim Zech, WTS Germany, and Jeff Soar, WTS UK, keynote speaker at next week’s ITR AI in Tax Forum 2026 in London
India is signalling flexibility on expat taxation to attract foreign expertise, though employers will need to navigate disclosure, treaty and scope uncertainties