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Publications & News


Court Of Appeal Allows Taxpayer To Claim Investment Tax Allowance And Industrial Building Allowance
Recently, the Court of Appeal in KPHDN v PSB upheld the High Court’s decision in allowing the taxpayer to claim Investment Tax Allowance...


Transfer Pricing and Cross-Border Financing: Lessons From The Singtel Case
Singapore Telecom Australia Investments Pty Limited (Singtel) v Commissioner of Taxation [2021] FCA 1597 is a recent transfer pricing...


Intra-Group Loan Pricing
Chevron Australia Holdings Pty Ltd v Commissioner Of Taxation (2017) FCAFC 62 The recent ruling by the Full Federal Court in Chevron...


Tax Authority’s Application To Reinstate A Company Dismissed By The High Court
Recently, the High Court dismissed an action commenced by the Director General of Inland Revenue (DGIR) among others against the...


High Court Grants Stay Of Proceedings To Taxpayer
Section 106(3) Income Tax Act 1967 reads: “In any proceedings under this section, the court shall not entertain any plea that the amount...
Pricing Adjustments Made To Median Pricing
Recently, the High Court dismissed the Director General of Inland Revenue’s (DGIR) appeal in a transfer pricing appeal. The key issue in...
The Wiramuda Case – Landmark Federal Court Ruling That Compensation Is Not Taxable
Recently, the Federal Court led by the Chief Justice unanimously ruled in favour of the taxpayer by ruling that Section 4C of the Income...
UK Supreme Court’s Ruling In The NCL Investments Ltd Case
Recently, the United Kingdom Supreme Court in NCL Investments Ltd v Revenue and Customs Commissioners [2022] 1 WLR 1829 dealt with the...
Transfer Pricing In The Software Industry: The Oracle India Case And Its Impact
Oracle India Pvt. Ltd. (Oracle India) v Deputy Commissioner of Income Tax W.P. (C) 7828/2010 is a transfer pricing dispute which...
Transfer Pricing Treatment Of Intangibles
The “unique and valuable” nature of intangibles makes it challenging to conduct a valuation due to the absence of comparables. This alert...
What Multinational Enterprises Should Know About BEPS 2.0
The OECD has updated BEPS 2.0 to address tax challenges arising from the digital economy and to introduce a global minimum tax to be...
Tax Deductibility Of Forest Expenditure & Forest Allowance
In this alert, our pupil, Tan Jia Hua from the firm’s Tax, SST and Customs Practice, discusses the deductibility of various expenses...
Can The Inland Revenue Board Appoint A Person As Its Agent?
The Director General of Inland Revenue has the authority to appoint a person to pay taxes on behalf of another taxpayer. This alert...
Judicial Review: Taxpayer Successfully Challenged Minister’s Refusal To Grant Tax Incentives
Recently, the High Court allowed the application for judicial review by BHP (a company) to quash the Minister of Finance’s (Minister)...
High Court Rules Agreement For The Installation Of Gas Compressor Is Subject To RM 10 Stamp Duty
Recently, the High Court ruled that the Collector of Stamp Duties has no basis to subject an agreement for the installation of a gas...
AMB v Ketua Pengarah Hasil Dalam Negeri
Recently in AMB v Ketua Pengarah Hasil Dalam Negeri, the SCIT allowed the taxpayer’s appeal and held that the borrowing costs incurred by...
Group Relief Claim: High Court Rules Taxpayer May Claim The Excess Losses
On 18 July 2022, the High Court ruled in favour of the taxpayer where it was held that the taxpayer could claim the excess surrendered...
Burden Of Proof In Transfer Pricing Disputes
The burden of proof in a civil litigation refers to the duty of the party to prove a fact or allegation in a dispute. This alert examines...
TP: Hypothetical Agreement Used to Determine Arm’s Length Price in Cross-Border Transaction
In the Commissioner of Taxation of the Commonwealth of Australia v Glencore Investment Pty Ltd , the Full Federal Court of Australia...
High Court Rules Business Sale Agreement Is Subject To Nominal Stamp Duty
On 25 May 2022, in a landmark ruling, the High Court ruled in favour of the taxpayer where it was held that a business sale agreement...
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