Oracle’s MAP, UN Agenda, India APAs: Transfer Pricing Report

Hello and welcome to the Transfer Pricing Report. I’m Caleb Harshberger, and this week ... a lot happened! Australia, Coca-Cola, the UN, India, and more.

Australia’s Federal Court crushed tax officials’ dreams of a domestic court decision on whether Oracle Australia’s licensing deal with an affiliate contained embedded royalties subject to withholding tax—after Tuesday’s ruling agreed to pause the case while Oracle pursued a MAP.

The ruling knocked down a lower court decision where the judge was swayed by ATO arguments that a ruling was needed to bring clarity to 15 other cases concerning embedded royalties and to help ease ...