Transfer pricing services

Capital Markets and IPO support services

Transfer Pricing

Transfer Pricing is typically one of the most significant tax issues for multinational groups, given its subjectivity and the increasing concern of tax authorities worldwide to ensure profits are not inappropriately shifted through non-arm’s length pricing.

In many jurisdictions, this has been exemplified by tax authority scrutiny of a number of arrangements, including particularly intellectual property, financing, procurement/marketing hub arrangements, and a continued general focus to ensure that they are not missing out on their "fair share" of the overall value chain's profits.


However, Transfer Pricing risks cannot be considered simply from the perspective of one jurisdiction: adopting a conservative position in one jurisdiction will put pressure on transfer pricing risks in other jurisdictions.

As such, a holistic and balanced approach is required - as well as the exercise of sound professional judgment and expertise.

KEY CONTACTS

Liam Delahunty
Director - Sydney

E: [email protected]
T:+61 2 8226 4704


How can we help you?

RSM's approach to managing risk

Transfer Pricing Services

In light of this context, RSM's approach is to assist multinationals in establishing a transfer pricing policy that is "fit for purpose", so the global value chain is remunerated appropriately and the support for this is appropriately documented.

This has four key benefits:

  • Reducing or potentially eliminating the exposure to penalties from an adverse transfer pricing adjustment;
  • Providing a basis upon which groups can demonstrate they have complied with accounting standards relating to "uncertain tax positions", particularly AASB Interpretation;
  • Significantly reducing the internal work that would otherwise be required, in the event of tax authority audit if no documentation was available;
  • Evidencing sound corporate governance.

RSM’s approach seeks to identify the optimal way to achieve these objectives, whilst ensuring an appropriate balance between managing transfer pricing risks and incurring costs to do so.

RSM capabilities

Our global Transfer Pricing capabilities include:

  • Conducting risk assessments of existing Transfer Pricing arrangements
  • Advising on different Operating Models and their effectiveness/appropriateness
  • Preparing Transfer Pricing policy frameworks
  • Transfer Pricing policy implementation support services, including cost allocation studies
  • Preparing Transfer Pricing documentation
  • Managing Country-by-Country Reporting compliance obligations
  • Preparing Business Restructuring "support files" to substantiate restructurings
  • Reviewing legal agreements to ensure legal form aligns with economic substance, including cost sharing agreements
  • Assisting in seeking Advance Pricing Arrangements with tax authorities
  • Assisting in responding to tax authority reviews

Transfer Pricing

COVID considerations

With specific regard to the impact of COVID, we are also equipped to advise clients as to how they can legitimately vary their intra-group arrangements in order to share the impact of any disruption in financial performance, and to facilitate the preservation of cash.

Capital Markets

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In this five part series, Belinda Crowley (Corporate Tax, Brisbane) will be taking us through important tax topics and their potential impacts on your business.

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25 October 2021
RSM is pleased to launch TP On Demand, a series of 10-minute videos, available 24/7. 

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On 8 October 2021, the OECD followed up on its 1 July 2021, announcement to reform international taxation and to address the tax challenges arising from the digitalization of the economy. In particular, the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (IF) has agreed on a two-pillar solution.

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25 February 2021
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12 November 2020
The Full Federal Court has largely dismissed the ATO's appeal against a September 2019 decision by Davies J in the transfer pricing case involving Glencore Investment Pty Ltd (“Glencore”).

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24 September 2020
Important technical amendments clarifying the operation of Australia’s hybrid mismatch rules received Royal Assent on 3 September 2020. Background

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The ATO has published much-awaited guidance in relation to outbound interest-free loans - which it has released for comment in Draft Taxation Ruling TR 2017/4 DC2.

Arm’s length debt test – New ATO position finalised

24 August 2020
The ATO has simultaneously published two documents which now represent the ATO’s views on the application of the arm’s length debt test (“ALDT”) in determining borrowing capacity.

OECD's Annual Corporate Tax Statistics Publication

17 July 2020
The OECD has released the 2nd edition of its annual Corporate Tax Statistics publication.

Australia adopts OECD 2017 Transfer Pricing Guidelines

10 July 2020
Australia’s transfer pricing legislation has now imported the most recent updates to the OECD's Transfer Pricing Guidelines as published on 10 July 2017.

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