Excerpt from the current ITB:
In Australia, the Full Federal Court has decided the Singtel transfer pricing case. The taxpayer company (an Australian resident) purchased 100% of the shares in an Australian operating company, from a non-resident company (For Co). The purchase price was funded by vendor finance – that is, a Loan Note in the amount of AUD 5.2 billion was issued by the taxpayer vendor, For Co, as consideration for the purchase.

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