During the relevant period Daihatsu Australia Pty Limited was an importer and wholesale distributor of motor vehicles and spare parts manufactured by Daihatsu Motor Corporation Limited, a company incorporated in Japan, which was at the relevant times a majority shareholder in Daihatsu Australia. In 2000 the the tax authorities issued Daihatsu Australia with a Notice of Amended Assessment for FY 1992 - 1996 where transfer pricing adjustments had been made to taxable income. In the letter accompanying the assessments it was noted that an audit had been conducted “with a particular focus on the consideration paid for imported vehicles for the period 1992 to 1997” and according to the tax authorities the price paid for these vehicles had been above the arm's length price. The price had therefore been adjusted downwards. Daihatsu filed a complaint that eventually ended up in the Federal Court. Judgement of the Court The Court upheld the assessment of additional income issued by the tax authorities ... Read more