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TRANSFER PRICING SETTLEMENTS MADE BY RIO TINTO

Rio Tinto reached an agreement with the ATO (Australian Tax Office) resolving a disagreement on interest used to pay an intra-group dividend in 2015; as well as the pricing of certain marketing transactions between Rio Tinto entities based in Australia and Singapore from 2010-2021. Another agreement was reached, by Rio Tinto, with the IRAS (the Inland Revenue Authority of Singapore) in relation to transfer pricing related to the same periods. This agreement includes a settlement payment to the ATO for additional tax of A$613m, in addition to the A$378m of tax paid in respect of the original amended assessments.

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DATE

DISPUTE EVENT

Transfer Pricing Management Fees

TOPIC

21 Jul 2022

Section 2231

Not Applicable

Settlement

CASE REFERENCE

Not Applicable

APPEALED CASE REFERENCE

2018/IT/rew

COURT

LAW OR TREATY

Income Tax

SECTION OR ARTICLE

JURISDICTION

Australia

Settlement

CATEGORY

Current Dispute

DECISION IN FAVOUR OF 

RIO TINTO

TAXPAYER

Issue settled based on compromise

OUTCOME

ISSUE

The transfer pricing of management fees

REVENUE AUTHORITY 

ATO

PUBLIC ENTITY

ATO

CASE LINK

SOURCE LINK

DETAILS

SUMMARY OF RIO TINTO SETTLEMENT


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