Our People

Danielle Sherwin
Principal - Sydney


Danielle is a Principal in the Tax Services division in the Sydney office.

Danielle has specialised in international taxation for the past 10 years, with a focus on transfer pricing and international tax.

Danielle has assisted her clients with their international tax planning and transfer pricing needs, ranging from Significant Global Entities (SGE) assessment, Country-by-Country (CBC) reporting, transfer pricing planning and advisory to transfer pricing compliance and documentation. She has worked with a broad spectrum of clients ranging from start-ups to listed multinational corporate groups. Her duties at RSM include liaising with clients on international issues, looking into technical legislation and teaching junior staff members.

"I love a challenge and learning new things."

Danielle has worked extensively with other firms in the RSM network to assist in the delivery of these services. Before joining RSM, she worked at Subway and still loves the smell of their bread!

Outside of work Danielle enjoys being active outdoors playing netball, touch football and going for bushwalks. She also loves making cocktails and recently made an (amateur) cocktail book.


Danielle has experience in transfer pricing and international tax, including but not limited to:  

  • tax consultantAssisting clients with their SGE obligations in Australia, including compliance with CBC Reporting regime
  • Co-ordinating global transfer pricing engagements within the RSM network for outbound structured entities;
  • Addressing the transfer pricing compliance needs of her Australian clients;
  • Conducting benchmarking analyses for a wide variety of transactions including loans, royalties, services etc.;
  • Assisting with the preparation and/or review of the International Dealings Schedule;
  • Assisting with transfer pricing adjustments required in the corporate income tax returns
  • Assisting with transfer pricing and Multinational Anti-Avoidance Law audits by the Australian Taxation Office; and
  • Assisting clients in addressing their transfer pricing compliance obligations in a practical and cost-effective manner.


Danielle has been involved in:

  • Assisting with the development of RSM protocols for SGE clients. 
  • Managing the Australian and outbound transfer pricing planning and compliance of ASX listed entities.
  • Finance structuring for an income tax and transfer pricing perspective for large inbound investments.
  • Defending clients from transfer pricing audits/reviews as well as Multinational Anti-Avoidance Law reviews by the Australian Taxation Office. 


  • Chartered Accountants Australia and New Zealand
  • Taxation Institute of Australia


  • Bachelor of Business and Commerce - Accounting (University of Western Sydney)
  • Master of Taxation Law (University of Sydney)





Tax Insights | November 2022 edition

30 November 2022
November 2022 edition The latest tax updates for you and your business Keep up to date with the latest Australian and International tax news from our market-leading experts. THE TAX LIBRARY Are you giving the gift of FBT this Christmas? Let us help you avoid the FBT hangover As the silly season gets underway and with many emplo...

Tax implications for significant global entities and country-by-country reporting entities

3 October 2022
Multinational groups with operations in Australia must understand the critical concepts of Significant Global Entity (SGE) and a Country-by-Country Reporting Entity (CbCRE) as these trigger numerous targeted integrity and tax transparency measures, and potentially a draconian penalty regime. Generally, this is targeted at larger groups with global revenues of more than A$1 billion.

'Treaty shopping’ a key focus area of the ATO

2 August 2022
The ATO recently released Taxpayer Alert (TA) 2022/2 Treaty shopping arrangements to obtain reduced withholding tax rates. TA2022/2 gives taxpayers due warning that ‘treaty shopping’ to obtain the benefit of a reduced rate of withholding tax (WHT) in relation to the payment of dividends or royalties from Australia is a key focus area of...

Tax Insights | June 2021 edition

30 June 2021
In our June edition of our Tax Insights we look at Taxation Ruling TR 2021/D4, R&D EOFY summary and more.

Taxation Ruling TR 2021/D4 - Income tax: royalties - character of receipts in respect of software

29 June 2021
The ATO has released an initial draft, for comment, of its updated guidance on the classification of royalties in relation to software, in TR 2021/D4. This has been long-awaited given the last version of this guidance is in TR 93/12, which has now been withdrawn effective from 1 July 2021. With the significant development in technology and gl...

Hybrid Mismatch Amendments

24 September 2020
Important technical amendments clarifying the operation of Australia’s hybrid mismatch rules received Royal Assent on 3 September 2020. Background In 2015, as part of the OECD/G20 BEPS Project, the OECD released the OECD Action 2 Report which made recommendations to neutralise the effects of hybrid mismatch arrangements. In the 2016-17...

The broadening of Significant Global Entity definition

26 May 2020
Broadening of Significant Global Entity definition and the potential impact for Australian entities with Private Equity ownership. Following new legislation which received Royal Assent on 25 May 2020, the definition of Significant Global Entity (SGE) has been expanded, and a new definition of Country-by-Country Reporting (CbCR) entity creat...

How does being a Significant Global Entity (SGE) affect my Australian tax obligations?

18 April 2019
The introduction of the concept of a significant global entity (SGE) was to increase the transparency of multinationals and was in line with the OECD’s Base Erosion and Profit Shifting (BEPS) initiatives. This concept is of significant importance as it triggers additional tax law obligations and significantly increased penalties.  A SGE i...