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
