RESEARCH & EDUCATION

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Developments
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.

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
