Transfer Pricing
Over the past five years there has been an increasing focus on transfer pricing by the Australian Taxation Office (ATO) and tax offices around the world. With an ever changing global economy, now more than ever before, multinational companies need to be conscious of the procedures and precautions required to avoid double taxation and the imposition of fines and penalty interest.
Transfer pricing provides an opportunity to optimise the value of the business by effective tax rate and franking credit management. However, governments and tax authorities, who exist to maximise tax revenue, are responding by strengthening legislation, demanding stricter documentation of transfer pricing practices, and requiring payment of penalties and interest for non compliance.
A transfer pricing audit by a tax office can potentially cause losses of of millions of dollars through double taxation, fines and interest. Turner Freeman's Transfer Pricing Team can help you actively manage tax strategies to maximise profits through multi jurisdictional compliance and supporting documentation systems.
The uncertainty of how transfer pricing arrangements will ultimately be treated by a tax office, Australian or foreign, makes Advance Pricing Arrangements (APAs) an attractive option and Turner Freeman's transfer pricing experts can also help your company negotiate unilateral, bilateral or even multilateral APAs with the ATO and other tax offices.
The combined knowledge and global experience of Turner Freeman's Transfer Pricing Team offers high level technical capabilities, a client focused culture and access to a global network of respected tax professionals.
Turner Freeman's approach encompasses not only pricing on tangible goods and services, but transfers of intangible assets or group financing.
Areas of expertise
- Unilateral and bilateral advance pricing arrangements
- Developing and implementing commercially viable transfer pricing policies
- Audit defence strategies
- Litigation counsel and administrative resolution
- Preparing and negotiating appropriate responses to revenue authority challenges, and Assessing the risk of revenue authority challenge