ALP

Arm's length principle

APA

Advanced Pricing Agreement

ATO

Australian Taxation Office

Commissioner

Commissioner of Taxation

CUP

Comparative Uncontrolled Prices (test)

Division 13

Division 13 of the Income Tax Assessment Act 1936 which contain transfer pricing rules

Division 820

Division 820 of Income Tax Assessment Act 1997 containing provisions on thin capitalisation

DTA

Double Tax Agreement

ITAA 1936

Income Tax Assessment Act 1936

ITAA 1953

International Tax Agreement Act 1953

ITAA 1997

Income Tax Assessment Act 1997

IT(TP) Act 1997

Income Tax (Transitional Provisions) Act 1997

MAP

Mutual Agreement Procedure

OECD

Organisation for Economic Co-operation and Development

OECD Guidelines

OECD's Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations

OECD Model

OECD Model Tax Convention on Income and on Capital

SNF case

Commissioner of Taxation v SNF (Australia) Pty Ltd [2011] FCAFC 74

TAA 1953

Taxation Administration Act 1953