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

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INCOME TAX - transfer pricing - whether consideration exceeded arm's length consideration - consideration that might have been reasonably expected between independent parties dealing at arm's length - meaning of property - meaning of consideration - what constitutes arm's length consideration for acquisition of property INCOME TAX - whether determinations excessive - whether decision by delegate without authority makes assessment excessive CONSTITUTIONAL LAW - retrospective effect of taxation legislation - whether retrospectivity results in arbitrary and incontestable tax

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