Tax Advisory and Structuring

We can advise our clients on all income tax issues, no matter how big or small, straightforward or complex. Our point of difference is we ensure our advice is not only technically correct, but is useful, based on facts and limited assumptions, and provides a realistic and balanced risk assessment that is capable of internal consumption and implementation.

At Nuwaru we have Partners that are technical experts and we have Partners that have worked as Heads of Tax in large corporates who understand what our clients really need.  When you get tax advice from Nuwaru, you get the benefit of our experience and expertise from both perspectives.  Where else can you get that?

Technical advice and opinions

We assist with:

  • Ad hoc GST advice from emails and memorandums to reports and complex opinions
  • Reasonably arguable position papers
  • Second opinions

Tax rulings

Drafting, reviewing and submission of ATO ruling requests

International Tax

We provide tax advice and support across the full range of international tax areas including tax residence and source, permanent establishments, foreign income exemptions and offsets, inbound or outbound structures and transactions, tax treaties, OECD BEPS policies, transfer pricing, thin capitalisation, withholding taxes, Controlled Foreign Corporations (CFC) rules, foreign taxes, and international tax structuring

Transaction support and structuring

We assist with:

  • Preliminary discussions and advice on structuring alternatives, key tax risks and suggested next steps
  • Ad hoc advice from emails and memorandums to reports and complex opinions
  • Second opinions on structuring advice
  • Review of supporting evidence and legal documentation

Internal documentation

Preparation and/or review of internal position papers, enhancement of existing documentation, preparation for an ATO review

Day-to-day assistance

Sounding board for senior management, guidance on likely implications, assistance in internal approvals processes, trips and traps

Direct tax sharing agreement

Preparation of a valid TSA including listing all contributing members and the head company, detailed allocation methodology, deed of accession and release deed

More Information

Pricing:

  • $1,500 to $3,000 depending on the turnover and number of entities in the group

Tax funding agreement

Preparation of a TFA that aligns with UIG 1052 and AASB 112, utilising the commonly used group allocation method

More Information

Pricing:

  • $1,500 to $3,000 depending on the turnover and number of entities in the group

Technical advice and opinions

We assist with:

  • Ad hoc advice from emails and memorandums to reports and complex opinions
  • Reasonably arguable position papers
  • Second opinions

Tax rulings

Drafting, reviewing and submission of ATO ruling requests

International Tax

We provide tax advice and support across the full range of international tax areas including tax residence and source, permanent establishments, foreign income exemptions and offsets, inbound or outbound structures and transactions, tax treaties, OECD BEPS policies, transfer pricing, thin capitalisation, withholding taxes, Controlled Foreign Corporations (CFC) rules, foreign taxes, and international tax structuring

Transaction support and structuring

We assist with:

  • Preliminary discussions and advice on structuring alternatives, key tax risks and suggested next steps
  • Ad hoc advice from emails and memorandums to reports and complex opinions
  • Second opinions on structuring advice
  • Review of supporting evidence and legal documentation

Internal documentation

Preparation and/or review of internal position papers, enhancement of existing documentation, preparation for an ATO review

Day-to-day assistance

Sounding board for senior management, guidance on likely implications, assistance in internal approvals processes, trips and traps

Direct tax sharing agreement

Preparation of a valid TSA including listing all contributing members and the head company, detailed allocation methodology, deed of accession and release deed

More Information

Pricing:

  • $1,500 to $3,000 depending on the turnover and number of entities in the group

Tax funding agreement

Preparation of a TFA that aligns with UIG 1052 and AASB 112, utilising the commonly used group allocation method

More Information

Pricing:

  • $1,500 to $3,000 depending on the turnover and number of entities in the group