Transfer pricing is considered the most important international tax issue facing businesses of companies operating across borders. The laws surrounding transfer pricing are becoming more complex, while multinational companies face greater scrutiny from regulators and the public.
Effective transfer pricing documentation is essential for good corporate governance among multinational corporations. By investing in comprehensive transfer pricing studies, Australian multinationals can ensure compliance with local regulations, mitigate tax risks, optimise tax efficiency, and enhance overall business operations.
Australia’s transfer pricing regime is progressive and operates on a self-assessed basis. Failing to have transfer pricing documentation, which documents your compliance with the arm’s length principle, can increase your risk profile with the ATO and raise your risk of an audit or penalties in the case of a transfer pricing adjustment.
If your organisation engages in international related party dealings, it’s common to lodge an International Dealings Schedule with your tax return and disclose relevant transfer pricing documentation for related party transactions. These disclosures flag to the ATO what level of transfer pricing documentation you have on hand.
Even if your international related party dealings constitute a small percentage of your transactions, large or high-risk taxpayers may be subject to regular reviews. It’s vital to navigate your risks carefully.
Engaging with experienced tax professionals who understand the global tax landscape will help ensure your organisation remains compliant across jurisdictions.
How we help clients
HLB's experienced professionals invest their time in getting to know your business needs and they go beyond simply avoiding the threat of double taxation. We assist by dealing with the various taxing authorities so that you can focus on your core business objectives.
Our highly regarded tax team specialises in all aspects of transfer pricing, including the preparation and lodging of documentation, as well as assisting clients with tax disputes.
We collaborate closely with your in-house finance and legal teams to develop and implement policies tailored to the size, geographical scope, and specific needs of your organisation.
Our comprehensive services include:
- Review and assessment: Evaluate your existing strategy.
- Documentation preparation: Prepare documentation in line with ATO requirements to assist in managing your risk. Assist and support in developing policies.
- Check your eligibility: Consider and document your eligibility to apply the simplified transfer pricing options.
- Audit assistance: Provide support during ATO risk reviews and audits, and help resolve tax disputes.
- International dealings schedule preparation: Assist with the preparation and review of international dealings schedule disclosures.
- Reporting: Prepare country-by-country reports, master files, and Australian local files required under BEPS.