Chevron Australia Holdings Pty Ltd v Commissioner of Taxation, [2017] FCAFC 62

Case tabs

Summaries

Summary Under

cross-border loan made on arm’s length terms would have benefited from a parent guarantee or other security

The U.S. subsidiary (“CFC”) of the taxpayer (“CAHPL” – which was an Australian subsidiary in the Chevron multinational group) borrowed...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Summary Under

cross-border loan interest improperly reflected lack of security

The U.S. subsidiary (“CFC”) of an Australian company (“CAHPL”) in the Chevron multinational group borrowed in the U.S. commercial paper...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Summary Under

retroactive tax was constitutional if it could be judicially challenged based on the facts

The U.S. subsidiary (“CFC”) of the Australian taxpayer (“CAHPL) borrowed in the commercial paper market at a borrowing cost of about 1.2%...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.