Multinational

Africa

The intercompany pricing of commodities: Alcoa versus the Australian Taxation Office

July 20, 2020

Dr. Harold McClure, an Economist based in New York City, discusses a transfer pricing dispute between the Australian Taxation Office and an Australian affiliate of US aluminum giant, Alcoa, which presents interesting questions regarding when comparable transactions should be considered uncontrolled transactions for transfer pricing purposes and how to select the best method for determining arm’s length prices for commodities such as alumina. . . .

Africa

Intercompany interest deductions in the extractive sector

July 15, 2020

Economist Dr. Harold McClure of New York City discusses the taxation of intercompany financing in the extractive sector, focusing on likely tax disputes concerning the financing of Australia’s Gorgon natural gas project, the UN’s recent guidance on transfer pricing in the extractive sector, and the ConocoPhillips and Chevron intercompany financing litigations . . .