Transfer pricing is one of the most challenging tax issues.

Multinational companies are increasingly facing scrutiny from regulators, media and the public. Complying with different requirements across multiple jurisdictions can be a complex and time-consuming task.

Grant Thornton’s transfer pricing team helps clients manage their entire transfer pricing lifecycle: from establishing a robust transfer pricing policy that supports corporate goals and strategies, to preparing and maintaining supporting documentation and agreements to satisfy tax regulations, and defending their transfer pricing policies before tax authorities using sophisticated economic arguments, research and databases.

We offer tailored solutions to your local and global transfer pricing needs, including:

  • establishing planning structures when expanding overseas for the first time or entering new markets
  • restructuring your transfer pricing framework for your changing supply chain needs
  • undertaking transfer pricing reviews to identify and manage your risks
  • conducting pricing of intercompany debt and arm’s length debt testing analysis
  • supporting your statutory reporting requirements, including country-by-country reporting
  • preparing and maintaining local, regional and global transfer pricing documentation.

We know that a robust transfer pricing strategy involves a mix of accounting, customs, logistics, tax consulting and economic analysis. Our expert advice encompasses these areas and considers transfer pricing in the context of international business. This means that we consider factors such as corporate structures, repatriation of profits, double tax treaties, global employee mobility, inbound and outbound investments and withholding tax.

You'll work with our transfer pricing team and have access to support from Grant Thornton’s global network of transfer pricing specialists. This collaborative approach brings you integrated, pragmatic and cost-effective global transfer pricing solutions and advice.

For any organisations who have supply chains of tangible goods and need to consider customs implications, head to Global trade and customs.

Our Transfer Pricing Services

ATO guidance and compliance

The Australian Taxation Office plays a pivotal role in shaping and enforcing transfer pricing compliance for businesses operating in Australia. Its guidance is designed to ensure that multinational enterprises adhere to the arm’s length principle when pricing cross-border transactions with related parties. By addressing ATO expectations early, uncertainty reduces and decision making improves.

Australian public country-by-country reporting requirements

Australia’s Public Country by Country (CbC) Reporting regime represents a significant step toward enhancing tax transparency for large multinational enterprises (MNEs). Effective for reporting periods starting on or after 1 July 2024, the regime requires certain entities to publicly disclose selected tax information, either on a country by country basis or in aggregated form.

Country-by-Country reporting

Country by Country Reporting is a key component of the OECD’s Base Erosion and Profit Shifting (BEPS) Action Plan, designed to enhance transparency in the global tax system. In Australia, CbC reporting obligations apply to Country by Country Reporting Entities, being multinational groups with annual global revenue of A$ 1 billion or more. We assist our clients in meeting their CbC reporting obligations by preparing compliant documentation, reviewing transfer pricing policies, and advising on risk mitigation strategies.

Intra-group financing

Intra-group financing arrangements are a critical transfer pricing focus area of the Australian Taxation Office (ATO). Our team offers comprehensive support in navigating intra-group financing challenges. As technical experts, we are across both ATO and OECD guidance on financial transactions.

Related party services

Related party services sit at the centre of transfer pricing compliance for multinational enterprises (MNEs) operating in Australia. Managing related party services is often complex, and our support can help your business move from compliance driven processes to confident, well reasoned positions.

Transfer pricing and global trade

Transfer pricing and customs duty intersect in complex ways that can significantly impact multinational enterprises engaged in cross-border trade. While transfer pricing focuses on ensuring that related-party transactions are conducted at arm’s length for income tax purposes, customs authorities are primarily concerned with the declared value of imported goods for duty assessment.

Transfer pricing for intellectual property, litigation and case law

Intellectual property (IP) sits at the heart of value creation for many businesses. That makes it a clear focus for the ATO, particularly where IP is migrated across borders or payments for rights are embedded in goods or services. What that means for your business is closer scrutiny and a need to clearly explain how value is created, who controls the IP and how returns are shared.

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