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.


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

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.

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. 

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.

New announcements to the 'JobKeeper Payments'

7 April 2020
In recent days, the Federal Government has made updates to the JobKeeper payment Fact Sheet, providing clarity surrounding eligibility for certain individuals and consolidated groups, and extending the eligibility criteria for eligible charities.

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:

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.

What foreign owners of residential property need to know about lodging their annual return

4 September 2018
In late 2017, the Australian Federal Government introduced an annual vacancy fee to be levied on  foreign owners of residential property, where the property is not occupied or generally available on the rental market for at least 6 months in a 12 month period. 

How the PM’s defeat impacts corporate tax rates

24 August 2018
Following the proposal for reduced tax rates for corporate entities in 2016, the Treasury Laws Amendment (Enterprise Tax Plan No 2) Bill 2017 (the Bill) was ultimately defeated in the Senate on 23 August 2018 by a vote of 36 to 30. 

Foreign incorporated companies and changes to the tax ruling - What you need to know.

20 August 2018
Most will remember the 2016 High Court ruling in the case of Bywater Investments Limited.

Reduced corporate tax rates - what rate of tax will my company pay?

27 July 2018
While the legislation is transitioning, some have been left confused about the application of reduced corporate tax rates and the details of eligibility criteria during this state of limbo. To provide some clarity, we take a closer look.

Fringe Benefits Tax – ATO finalise their position on private use of vehicles.

18 July 2018
New guidelines for private use exemptions of eligible motor vehicles for Fringe Benefits Tax (FBT) - ATO says yes to making a quick stop to grab a coffee (as long as it doesn’t add more than 2kms to your trip to work and is infrequent) but no to heading to cricket practice after work. 

R&D Tax Incentive Reform - Call for submissions

4 July 2018
R&D tax reforms, as announced in the 2018-19 Federal Budget, are steps closer to implementation with the Treasurer and Minister for Jobs and Innovation releasing draft legislation proposed to enact the changes. 

New GST withholding rules - what property purchasers and developers need to know

24 May 2018
The Federal Government has passed legislation that will require purchasers of new residential properties to remit the GST directly to the Australian Taxation Office (ATO) as part of settlement. The measures were first announced in last year’s Federal Budget. The legislation specifies: 

Budget falters on R&D tax (and how this impacts startups)

24 May 2018
It’s the third budget handed down by Treasurer Scott Morrison and for those of us in the innovation space, a whole lot to digest. After poring over the detail, I’ve created a summary of notable items for your reading pleasure (disclaimer: it’s not all pleasant).

ATO extends lodgement date for Country-by-Country Reporting

24 November 2017
The Australian Taxation Office (“ATO”) announced this week an extension of the due date for lodgement of the Country-by-Country report, master file and local file (collectively “CbCR”), from 31 December 2017 to 15 February 2018 for taxpayers with an income year ended on 31 December 2016.