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Transfer Pricing

Streamlined Transfer Pricing Solutions in Australia

Highly efficient transfer pricing strategies

In the ever-evolving, complex landscape of transfer pricing, proficiency and adaptability are paramount. As an Australian business, contending with local revenue authorities represents merely a fraction of the transfer pricing challenges you may encounter.

The construction of commercially feasible and defensible transfer pricing strategies to reinforce your tax position, both locally and globally, presents further technical intricacies. Our expert team is dedicated to delivering comprehensive transfer pricing solutions that are clearly articulated and business-focused.

Our goal is to make sure your transfer pricing structures are not just efficient but are also pragmatically prepared to tackle potential challenges and complexities. We are committed to identifying and minimising your transfer pricing risks before they arise.

Our focus lies in keeping you one step ahead of legislative amendments and crafting a sustainable solution that both protects and propels your business.

Our Expertise in Transfer Pricing Services:

Evaluating and diminishing permanent establishment risk
Developing cross-border expansion strategies
Administering the global effective tax rate
Structuring global business organisations
Assisting with investments into Australia
Advising on intellectual property matters
Crafting commercialisation structures

The Andersen Global Advantage

Andersen is an independent tax and legal firm with a worldwide presence through the member firms and collaborating firms of Andersen Global.

Our transfer pricing team is closely connected, working as ONE FIRM together across multiple jurisdictions. With Andersen, you gain access to trusted partners who ensure your business operations are protected and supported through times of expansion, change and regulatory challenges.

Related Insights

Transfer Pricing for the International Practitioner: Australian perspective

The following is the Australian section of the Fall 2023 Transfer Pricing Forum, reproduced with permission from Transfer Pricing Forum. 13 TPTPFU 1, 10/19/23. Copyright

Five practical TP examples for SMEs to safeguard their TP position.

In the fourth transfer pricing podcast with Tax Talks, we link the previous three episodes by providing a few transfer pricing examples to cover common

Monthly Tax Update July 2023

In the July 2023 edition of Andersen in Australia’s Monthly Tax Update, we provide the recent updates in legislation along with tax developments in the

Podcast: TP Reasonably Arguable Position RAP

Featured on: TAX TALKS This podcast was done in conjunction with Tax Talks on the key principles of Transfer Pricing. Listen now: Having a reasonably

ATO’s Assessment of the Advance Pricing Agreement (APA) Program

The ATO releases its assessment of the Advance Pricing Agreement (APA) program. Inside you will find What are APAs The ATO Review Findings Report Next

Podcast: Tax Talks on Simplified Transfer Pricing Record Keeping

Featured on: TAX TALKS This podcast was done in conjunction with Tax Talks on the key principles of Transfer Pricing. Listen now: Simplified transfer pricing

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Frequently Asked Questions

How does the ATO choose taxpayers for transfer pricing audits and what triggers these audits?

The ATO uses data from IDS, CbCR, and ITRs, along with AI tools like ANGIE, to identify non-compliance in transfer pricing by focusing on factors like IRPD amounts and adherence to the arm’s length principle. Discover the ATO’s data-driven approach for transfer pricing audits.

What Are the Key Criteria to Meet for Simplified Transfer Pricing Record Keeping (STPREK)?

To qualify for STPREK, a transaction must meet one of seven criteria, focusing on aspects like business size, transaction types, and specific financial thresholds, with each criterion applicable only to certain transactions. Explore the criteria for STPREK eligibility.

What Does the Glencore Case Teach About Documentation in Transfer Pricing?

The Glencore case highlights the need for meticulous documentation in transfer pricing, emphasising evidence on transaction facts, analysis of comparables, and verifying arm’s length arrangements, influencing how courts view Division 13 and Subdivision 815-A. Learn about the impact of Glencore on transfer pricing documentation.

Why Did the ATO Undertake a Review of the Advance Pricing Agreement (APA) Program?

The ATO reviewed the APA program due to concerns about its management, including audit-like early stages, aggressive approaches, lengthy negotiations, understaffing, and lack of transparency, all contributing to significant delays in processing APAs. Discover the reasons behind the ATO’s APA program review.

What Methods Does the ATO Use in Transfer Pricing Audits, and How Do Courts Decide on These Disputes?

During transfer pricing audits, the ATO follows methods outlined in legislation and Practical Compliance Guidelines, focusing on arm’s length conditions and risk ratings. Courts, as seen in cases like Roche Products Ltd. and SNF Australia, prefer transaction-based methods and critically assess OECD Guidelines’ applicability. Explore ATO’s audit methods and court decisions in transfer pricing.

How Can You Establish a Reasonably Arguable Position in Transfer Pricing?

Achieving a reasonably arguable position involves three steps: self-assessing your transfer pricing stance against the arm’s length principle, checking eligibility for Simplified Transfer Pricing Record Keeping, and preparing contemporaneous compliant documentation, whether qualifying for simplified methods or not. Learn how to secure a reasonably arguable position in transfer pricing.

What Are Practical Transfer Pricing Scenarios for SMEs in Australia?

Five common scenarios for SMEs include: 1) Inbound distributors qualifying for the Distributor Option in STPRK, 2) Handling low performance or losses, 3) Managing inbound intercompany loans under STPRK, 4) Dealing with low-value intragroup services and safe-harbour mark-ups, 5) Adapting transfer pricing methodologies for start-ups evolving into different business models. Explore practical transfer pricing examples for SMEs

How are Transfer Pricing Policies Developed?

Transfer pricing policies are developed through a detailed analysis of intercompany transactions, ensuring they adhere to the arm’s length principle. This involves selecting appropriate transfer pricing methods, evaluating comparable market data, and documenting these processes in compliance with international guidelines and local tax laws. The policy is then continually reviewed and adjusted to reflect changes in business operations and regulatory environments.

How Do Companies Prepare for a Transfer Pricing Audit?

To prepare for a transfer pricing audit, companies meticulously gather and organize relevant documentation, and conduct thorough reviews of their transfer pricing policies and transactions to ensure compliance with the arm’s length principle.