Top Australian Court Dismisses Singtel’s Transfer Pricing Appeal

A Singaporean company’s purchase of one of Australia’s largest telecommunication operators wasn’t conducted at arm’s length, and thus can’t claim a transfer pricing benefit, a top Australian court ruled.

The Full Federal Court of Australia dismissed Singapore Telecommunications’s appeal Friday over the company’s claim for a benefit for deductions based on interest paid on loans in its acquisition of Optus.

The Australian Tax Office first contested certain deductions in 2016 in a loan agreement of A$5.2 billion ($3.45 billion) that Singapore Telecom Australia Investments (STAI) had with British Virgin Islands-registered subsidiary SingTel Australia Investments (SAI) to purchase Cable and ...