RSM Australia

Our People

Liam Delahunty
Partner - Sydney


Liam is a Director of the Tax Services division in Sydney. With over 17 years of experience, principally in a Big 4 environment, he leads the International Tax and Transfer Pricing practice at RSM Australia. Based in Sydney since 2010, he has previously worked in London and New York.

Liam is responsible for providing transfer pricing and international tax compliance and advisory services to clients - from large multinationals to start-ups – to help them navigate the range of existing and emerging tax risks that arise for groups operating cross-border.

Although focussing on Australian tax law, he also is familiar with a range of foreign tax jurisdictions, including the UK, USA, Europe, Singapore, Hong Kong and China. Liam also has a good understanding of a range of accounting and corporate law issues.

Liam Delahunty is a partner of RSM Australia Partners and a Director of RSM Australia.


Liam provides international taxation services in the following areas:

  • Transfer pricing
  • Financing
  • Business restructuringasset_33.png
  • Offshore expansion
  • Intellectual property optimisation
  • OECD BEPS project issues
  • Hybrid mismatch arrangements
  • Diverted profits tax
  • Multi-national anti-avoidance
  • Double tax treaty issues
  • ATO engagement


Having an earlier background in computer programming, Liam has focussed on Technology, Media and Telecommunications clients in particular, but has advised clients in a broad range of industries.

Liam's clients have included Twitter, Uber, Snap, Cargill, BP, Canon, ResMed, Lloyd’s, Fonterra, Boart Longyear, SingTel Optus, Pfizer, Anheuser-Busch InBev, Broadspectrum, APN News & Media, Harvey Norman and a variety of SMEs.


  • Chartered Accountant, Charted Accountants Australia and New Zealand (CAANZ)
  • Legal Practitioner, Law Society of New South Wales


  • Bachelor of Commerce (Accounting)
  • Bachelor of Laws
  • Solicitor of the Supreme Court of New South Wales
  • Solicitor of the High Court (England and Wales)
  • Solicitor of the High Court (New Zealand)

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...

Transfer pricing issues during COVID-19

11 May 2020
The adverse impact of COVID-19 on a large number of businesses requires no introductory comment, as their focus turns to survival and cash preservation. Transfer pricing may not naturally be seen as an immediate concern for a number of multinational groups dealing with these key imperatives. However, as other recessions have demonstrated, transf...

COVID-19 and transfer pricing issues: Potential JobKeeper Payment Implications

5 May 2020
COVID-19 has had a very adverse impact on the cash flows of many Australian businesses, who will be looking closely at the JobKeeper Payment regime and whether their turnover has declined by the requisite percentage.  Further details are available via the RSM Coronavirus Resource Centre viewed here. Australian businesses that a...

COVID-19 and transfer pricing issues: Financing

5 May 2020
COVID-19 has had a pervasive effect on business and one of the most salient is its impact on a company’s cash flow and funding arrangements. We have separately discussed general transfer pricing issues – here we consider the implications to Australian companies working capital management as well as new and existing long-term funding arrange...

TA 2020/1 - Intangibles: Is your remuneration correct?

28 January 2020
The Australian Taxation Office (ATO) has released its first Taxpayer Alert of the decade in TA 2020/1, which identifies two principal concerns regarding intangibles: arrangements related to the development, enhancement, maintenance, protection and exploitation of intangible assets (known as the DEMPE functions) that have not properly remunera...

Simplified Transfer Pricing Record Keeping (STPRK) options for loan

18 September 2019
On 11 September 2019, the ATO released an update to Practical Compliance Guideline (“PCG”) 2017/2, in respect of Simplified Transfer Pricing Record Keeping (“STPRK”) options for lower-risk transactions. The changes relating to the safe harbour rate on “low-level” inbound and outbound loans, and now provide for 2.33% as the maximum ra...

Glencore prevails over ATO in transfer pricing dispute – appeal likely to follow

10 September 2019
On 3 September 2019, the Federal Court (at first instance) found in favour of Glencore in its transfer pricing dispute with the ATO, regarding the pricing of copper concentrate supplied by Glencore’s Australian group to its Swiss parent. The ATO had argued that the actual agreement between the parties was not consistent with what indepen...

Australia's hybrid mismatch regime

7 May 2019
In response to recommendations by the Organisation for Economic Co-operation and Development (‘OECD’) in Action 2 of it's Base Erosion and Profit Shifting (‘BEPS’) initiative in 2015, Australia has now enacted a new hybrid mismatch regime that generally applies to income years commencing on or after 1 January 2019. The rules apply broa...

International Tax and Transfer Pricing event series

Perth | Brisbane | Melbourne | Sydney
An event series on the international tax and transfer pricing landscape. The last few years have witnessed arguably the most significant changes to the International Tax and Transfer Pricing landscape in global history. Tax authorities are more connected, more sophisticated and more assertive. Never has it been more complex and challenging t...