Transfer Pricing Advice and Solutions
The global transfer pricing environment is fast-changing and complex. But understanding the risks involved in your related party cross border transactions is essential to meeting your regulatory requirements. This is particularly true in Australia which is widely acknowledged to be the strongest transfer pricing and anti-profit shifting regime in the world.
Australia’s transfer pricing provisions can be onerous. But Delve Innovation's specialists have the practical, proactive and innovative solutions that can take a complex situation and turn it into a solutions-based opportunity.
What is Transfer Pricing?
Transfer pricing regulations control how Australian businesses transact with their related parties overseas. In Australia this requires you to maintain complex documentation. This requires Australian entities to demonstrate the arm’s length nature of the costs associated with the dealings and show the dealings themselves are in accordance with the arm’s length principle. And it’s neither a simple nor an easy task.
About Delve’s Premier Transfer Pricing Experts
Australia’s transfer pricing provisions can be a burden on companies involved in international related party dealings. And the transfer pricing environment is fast moving and fast changing.
Delve’s transfer specialists are widely acknowledged as Australia’s premier transfer pricing specialists. In fact, our team was engaged by the ATO in their own audit of international related party dealings, to advise on the arm’s length nature of IP, licensing and service arrangements within Australian subsidiaries of multinationals.
Who Does it Impact?
Many organisations believe that transfer pricing only impacts the ‘big end of town’ or only applies to specific transactions. But Australia’s transfer pricing requirements apply to small to medium-sized enterprises (SMEs) in the same way they apply to larger multinationals.
This means that SMEs are getting more and more of the ATO’s attention. Many SMEs are simply unprepared and under resourced to handle the extent of the ATO’s enquiries when it comes to a review of their international related party dealings.
How We Help You
AT Delve Innovation we have the breadth of experience and depth of expertise to help you navigate your way through the transfer pricing minefield, in a practical and cost-effective manner. Our team always remains fully apprised and up-to-date with any changes so we can offer you innovative solutions that ensure you aren’t bogged down in unworkable arrangements, and can take advantage of opportunities as they arise.
All of our solutions are actionable – you’ll be able to implement and monitor them to ensure that your organisation has achieved its desired outcomes.
Specific Transfer Pricing Services
Transfer Pricing Risk Review
A review of your current transfer pricing documentation to ensure that your transfer pricing risk has been properly addressed. This can be particularly useful when a ‘Big 4’ associate has completed your preparation with limited partner oversight.
CbC Compliance Assessment and Exemption Assistance
Delve’s experts can help you identify and address situations where your Australian CbC reporting obligations are triggered despite your parent entity not being obligated. We can also help you request an exemption from the Commissioner for those reporting obligations.
Preparation of Transfer Pricing Documentation
Delves’s transfer pricing specialists can assist both SMEs and larger multinational enterprises to prepare appropriate transfer pricing documentation, including master files and local files.
SME Assessment
We can assist SMEs to determine whether they comply with any of the concessions contained in the ATO’s ‘safe harbour’ rules. We can then simplify the transfer pricing documentation obligations for you.
Tax Audit Assistance
We have internal insight into the ATO’s processes and procedures and the deep technical expertise to help you successfully navigate an ATO risk review or audit. We’ll help you get the best possible outcome, while minimising your exposure to tax and penalties.
Your Transfer Pricing Specialists
Transfer pricing is our specialty, and it’s the key to unlocking exceptional outcomes for our clients.
When you work with the Delve Innovation team, you aren’t handed off to more junior staff at the earliest possible opportunity. Our ‘director approach’ service means you have access to considered, evidence-based advice from senior industry leaders throughout your working relationship with us.
We can work with you to develop transfer pricing policies and documentation that are flexible, in line with your tax planning and completely defensible.
