RSM Australia

Our People

Danielle Sherwin
Principal - Sydney


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 SGE assessment, 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. 

Danielle has worked extensively with other firms in the RSM network to assist in the delivery of these services.asset_31.png


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

  • Assisting clients with their SGE obligations in Australia, including compliance with Country-by-Country 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)
  • Master of Taxation Law (University of Sydney)





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...