Transfer pricing
The transfer pricing landscape in Australia has fundamentally shifted with the introduction of a new transfer pricing legislative regime, as 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:
Governance
Implementing policies, processes and controls that support the accurate and efficient operation of transfer pricing.
Support
Assistance with navigating ATO transfer pricing reviews and enquiries.
Risk mitigation
Preparing evidence and documentation that supports your transfer pricing position.
Validation
Validating the pricing of cross-border transactions with related parties to ensure you are paying the right amount of tax in each jurisdiction.
Disclosure
Evidence that disclosures made in financial statements, income 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.
- 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
Partner Brisbane
Aileen O'Carroll
Partner Melbourne
Michael Minter
Managing Partner Newcastle and Hunter
Leon Mok
Managing Director Perth
