EY has also developed a separate CbC reporting tool “CbCR Web™” that helps you generate CbC reporting data, as required under BEPS Action 13 and the specific Australian obligations. Given our deep Australian TP expertise and knowledge of tax authority expectations, we work with you to ensure your disclosures are appropriate with the right levels of support in place, managing TP risks in real time.

Our transfer pricing advisory offering transforms TP from a year‑end obligation into a real‑time strategic capability. Recognising that businesses are constantly evolving, we partner with inbound and outbound clients to design defensible, commercially aligned and future proof pricing policies that reflect how business truly operates.

We work with clients to refresh their transfer pricing policies in a way that better reflects an evolving business reality. This includes embedding such policies with operational ‘guardrails’ for all group entities; and modifying systems to ensure alignment between commercial practice, accounting and tax. We work with you to develop, embed and implement TP policies that align with your business objectives by integrating models into ERP and invoicing systems, standardising contracts and workflows, and ensuring the organisation speaks a consistent TP language. Because great TP doesn’t stop at implementation, we also build monitoring frameworks that test outcomes through the year, apply analytics to spot variances early, and enable course‑corrections to be included in your supporting documentation before audit exposure arises.

Whether shaping TP policy and operationalising it globally, supporting a business restructure or navigating APAs, MAPs, or audits, our team brings the innovation, credibility, and commercial insight needed to stay ahead in a rapidly changing global tax environment. Strong system integration ensures alignment between your ERP, TP data, and reporting needs, supporting an ‘audit‑ready’ position for any review.

Operationalising transfer pricing models remains challenging – and its under more scrutiny than ever. EY has developed a structured and scalable framework that sharpens implementation and delivers results. Operational transfer pricing is more than just automation - strong operational transfer pricing foundations are essential in delivering accurate transfer pricing policies within a robust governance environment, with real time intercompany diagnostics providing a health check of a company's transfer pricing systems and processes to minimize leakages and maximise efficiencies.

Our team stands out in the market for its unmatched and differentiating expertise in dealing with tax regulators. Members of our team have deep experience at senior levels of the ATO, including in the role of competent authority and can bring significant insight and perspective on managing controversy as part of an overall strategy of engagement with the regulator. We are known for our strong regulator relationships, and our reputation as a trusted adviser where we navigate ATO processes to mitigate and resolve transfer pricing disputes. In this regard, we have significant experience in successfully negotiating Advance Pricing Agreements and resolving TP disputes, including through Mutual Agreement Procedures.