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Transfer pricing

Our team of transfer pricing specialists will work with you to ensure your transfer pricing aligns with your commercial requirements, reporting obligations and your global tax strategy.
Transparency in transfer pricing

The transfer pricing landscape in Australia has fundamentally shifted with the introduction of a new transfer pricing legislative regimeas well as persistent legislative reforms triggered by the OECD’s Base Erosion and Profit Shifting (BEPS) project. This has prompted a significant increase in reporting and transparency across multinational enterprises, along with an escalation in tax authority review and audit.

It is now more important than ever to ensure that your transfer pricing risks are effectively managed both in Australia and internationally. Regardless of the transaction, you must ensure correct pricing while also supporting the price through documentation that complies with transfer pricing laws and tax authority guidance in each location.

The value of transfer pricing advice

Any Australian business that operates with related entities outside of Australia will be impacted by transfer pricing. From Australian private or public entities expanding or operating offshore to foreign owned entities operating in Australia, our transfer pricing specialists can assist with 


Implementing policies, processes and controls that support the accurate and efficient operation of transfer pricing. 


Assistance with navigating ATO transfer pricing reviews and enquiries.  

Risk mitigation

Preparing evidence and documentation that supports your transfer pricing position.  


Validating the pricing of cross-border transactions with related parties to ensure you are paying the right amount of tax in each jurisdiction. 


Evidence that disclosures made in financial statementsincome tax returns and CbC reporting are supportable.

Penalty mitigation

Preparing transfer pricing documentation that meets specific criteria and can provide penalty mitigation in the event of an ATO adjustment. 

How can we help?
  • Governance and transfer pricing risk management frameworks, including design, implementation and testing of controls
  • Establishment of transfer pricing policies
  • Economic analysis, including benchmarking to support pricing of transactions
  • Documentation and evidence to support transfer pricing positions
  • Preparation of penalty mitigation transfer pricing documentation
  • Cross-border disclosures in income tax returns and financial statements
  • Preparation and lodgement of CbC reporting obligations
  • Transfer pricing dispute resolutions
  • Negotiation of and annual compliance in relation to advance pricing arrangements

Our experts

Simon Chun

Simon Chun



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Aileen O'Carroll

Aileen O'Carroll



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Michael Minter

Michael Minter

Managing Partner

Newcastle and Hunter

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Leon Mok

Leon Mok

Managing Director


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Howard Badger

Howard Badger



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