Tax & Law
- About Our Global Tax Services
- Country Tax Advisory
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- Transfer Pricing and Operating Model Effectiveness
- Indirect Tax
Transfer Pricing and Operating Model Effectiveness
We bring you a global perspective based on our long-standing experience of what really works in transfer pricing and operating model effectiveness (OME).
Our multi-disciplinary Operating Model Effectiveness teams work with you on operating model design, business restructuring, systems implications, transfer pricing, direct and indirect tax, customs, human resources, finance and accounting. We can help you build and implement the structure that makes sense for your business, improve your processes and manage the cost of trade.
Our transfer pricing professionals help you build, manage, document, review and defend your transfer pricing policies and processes -- aligning them with your business strategy. Our talented people work with you to build the proactive, pragmatic and integrated strategies that address the tax risks of today's businesses and help your business achieve its potential.
How we can help you:
- Strategy and policy development
- Governance optimisation and decision making process to help:
- Reduce impact of year-end adjustments
- Monitor transfer pricing footprint
- Coordinate across organisation
- Global or regional assistance to support transitions to new documentation requirements
- Controversy risk assessment, remediation or mitigation as a result of documentation requirements
- Global transfer pricing controversy and risk management
On 7 February 2018, the ATO released a draft practical compliance guide (PCG 2018/D2) relating to Australia’s Diverted Profits Tax. Although further work is needed on PCG 2018/D2 and LCG 2017/D7, it is a positive development and will assist businesses to: Calibrate the risk of ATO DPT questions during ATO compliance activities; Prepare for the approaches and issues the ATO will target; Consider proactive approaches to the ATO DPT team if desired, to reduce later controversy risk.
On 21 April 2017 the Full Federal Court (Court) delivered its judgement rejecting an appeal in a significant transfer pricing case involving an Australian subsidiary and the Australian Taxation Office (ATO).
Australia's Diverted Profits Tax Bill: includes updated transfer pricing guidelines and increased penalties
Australian and multinational significant global entities will be affected by a Bill introduced into Parliament on 9 February 2017.