Transfer Pricing

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Transfer Pricing

At WTS Australia, we have the best and most experienced state tax experts in Australia, with expertise in stamp duties, land tax, and payroll tax across all Australian jurisdictions.

Stamp duty is often that forgotten tax that comes in late and kills a deal. We think about stamp duty at the beginning of a transaction we are involved in, not the end, meaning we structure transactions to optimise the outcome, not let it impede a transaction at the 11th hour.

What do we offer?

We can assist with:

  • Technical advice and analyses
  • Permanent establishment revenue and cost allocations
  • Corporate, partnership and trust transfer pricing
  • Evaluation of pricing structures for international transactions
  • Tax authority engagement, reviews, investigations, audit defence, dispute management and resolution
  • Unilateral, bilateral and multilateral Advance Pricing Agreements (APAs) and similar Competent Authority negotiations
  • Independent reviews / second opinions including due diligence, modelling, and transaction support
  • Expert witness services
  • Litigation support, including in respect of TP, domestic controlled transactions, debt capacity and arm’s length debt analyses, IP infringements, etc.
  • Support for board decision making
  • TP compliance and process improvement
  • TP agreements, policies and governance
  • On Call TP Director and TP outsourcing partner
  • TP automation support
  • Global, regional or country-specific transfer pricing benchmarking analyses and documentation
  • Country-by-Country Reports compliant with OECD BEPS Action 13 requirements – including filing in Australia and / or New Zealand
  • Master File and Local File transfer pricing documentation compliant with OECD BEPS Action 13 requirements and / or local jurisdiction requirements, practices and nuances – including global, regional and/or local documentation
  • Australian-specific CbC Reporting Local File (including all components, i.e., Short Form, Part A and Part B) – including lodgment with the ATO
  • Risk assessment under Australian practical compliance guidelines
  • Support with Australian Reportable Tax Position schedule, International Dealings Schedule, etc
  • Support with New Zealand BEPS Disclosure Form, International Questionnaire, etc
  • Pricing of domestic controlled transactions for domestic tax law or other purposes
  • Analyses for competition law purposes
  • Analyses around debt capacity and arm’s length debt amounts
  • Debt vs. equity qualitative and quantitative analyses
  • Cost allocations
  • Market analyses
  • IP analyses for exploitation-related structuring and pricing, IP infringement disputes, financial statement impairment analyses, etc
Teena Ingram
Teena IngramPartner | Corporate Tax

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