Menu

Transfer Pricing

We have extensive expertise in providing specialised transfer pricing services across a comprehensive range of multinational organisations and industries on a global basis.

Our versatile and broad portfolio of services address global strategic, operational and compliance-based economic / international and domestic pricing matters and risks.

Advisory, guidance and decision support

We can assist with:

  • Technical advice and analyses
    • Permanent establishment revenue and cost allocations
    • Corporate, partnership and trust transfer pricing
  • Evaluation of pricing structures for international transactions
  • Tax authority engagement, reviews, investigations, audit defence, dispute management and resolution
  • Unilateral, bilateral and multilateral Advance Pricing Agreements (APAs) and similar Competent Authority negotiations
  • Independent reviews / second opinions including due diligence, modelling, and transaction support
  • Expert witness services
  • Litigation support, including in respect of TP, domestic controlled transactions, debt capacity and arm’s length debt analyses, IP infringements, etc.
  • Support for board decision making

Risk management

  • TP compliance and process improvement
  • TP agreements, policies and governance
  • On Call TP Director and TP outsourcing partner
  • TP automation support

Compliance

  • Global, regional or country-specific transfer pricing benchmarking analyses and documentation
  • Country-by-Country Reports compliant with OECD BEPS Action 13 requirements – including filing in Australia and / or New Zealand
  • Master File and Local File transfer pricing documentation compliant with OECD BEPS Action 13 requirements and / or local jurisdiction requirements, practices and nuances – including global, regional and/or local documentation
  • Australian-specific CbC Reporting Local File (including all components, i.e., Short Form, Part A and Part B) – including lodgment with the ATO
  • Risk assessment under Australian practical compliance guidelines
  • Support with Australian Reportable Tax Position schedule, International Dealings Schedule, etc
  • Support with New Zealand BEPS Disclosure Form, International Questionnaire, etc

Economic/financial analyses and benchmarking

  • Pricing of domestic controlled transactions for domestic tax law or other purposes
  • Analyses for competition law purposes
  • Analyses around debt capacity and arm’s length debt amounts
  • Debt vs. equity qualitative and quantitative analyses
  • Cost allocations
  • Market analyses
  • IP analyses for exploitation-related structuring and pricing, IP infringement disputes, financial statement impairment analyses, etc

Advisory, guidance and decision support

We can assist with:

  • Technical advice and analyses
    • Permanent establishment revenue and cost allocations
    • Corporate, partnership and trust transfer pricing
  • Evaluation of pricing structures for international transactions
  • Tax authority engagement, reviews, investigations, audit defence, dispute management and resolution
  • Unilateral, bilateral and multilateral Advance Pricing Agreements (APAs) and similar Competent Authority negotiations
  • Independent reviews / second opinions including due diligence, modelling, and transaction support
  • Expert witness services
  • Litigation support, including in respect of TP, domestic controlled transactions, debt capacity and arm’s length debt analyses, IP infringements, etc.
  • Support for board decision making

Risk management

  • TP compliance and process improvement
  • TP agreements, policies and governance
  • On Call TP Director and TP outsourcing partner
  • TP automation support

Compliance

  • Global, regional or country-specific transfer pricing benchmarking analyses and documentation
  • Country-by-Country Reports compliant with OECD BEPS Action 13 requirements – including filing in Australia and / or New Zealand
  • Master File and Local File transfer pricing documentation compliant with OECD BEPS Action 13 requirements and / or local jurisdiction requirements, practices and nuances – including global, regional and/or local documentation
  • Australian-specific CbC Reporting Local File (including all components, i.e., Short Form, Part A and Part B) – including lodgment with the ATO
  • Risk assessment under Australian practical compliance guidelines
  • Support with Australian Reportable Tax Position schedule, International Dealings Schedule, etc
  • Support with New Zealand BEPS Disclosure Form, International Questionnaire, etc

Economic/financial analyses and benchmarking

  • Pricing of domestic controlled transactions for domestic tax law or other purposes
  • Analyses for competition law purposes
  • Analyses around debt capacity and arm’s length debt amounts
  • Debt vs. equity qualitative and quantitative analyses
  • Cost allocations
  • Market analyses
  • IP analyses for exploitation-related structuring and pricing, IP infringement disputes, financial statement impairment analyses, etc

Leslie Prescott-Haar

leslie.prescotthaar@nuwaru.com

(+64) 274 516 646

Sophie Day

sophie.day@nuwaru.com