Australia: Transfer Pricing

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Tax law and international tax law thought leadership, articles, podcasts, videos and webinars from expert sources across the legal world. Explore insights covering topics such as capital gains tax, corporate tax, income tax, inheritance tax, national insurance, property taxes, sales taxes, VAT, GST, tax authorities, transfer pricing and withholding tax.

JONES DAY PRESENTS®: Navigating Australia's Toughening Tax Controversy Landscape (Video)

Australia's tax controversy landscape is becoming increasingly difficult for multinationals to navigate, with the Australian Taxation Office ("ATO") adopting sophisticated, assertive positions that test the limits of the law. Jones Day partners Lauren Moses and Niv Tadmore discuss the ATO's focus on transfer pricing, intangibles, and other cross-border issues, and they explain why understanding what drives the ATO is key to resolving disputes efficiently.

JD

Jones Day

Cross-border software payments and royalties: implications of final taxation ruling and practical compliance guideline Read More

The Australian Taxation Office has issued its final ruling on cross-border software payments, dramatically expanding what constitutes a royalty subject to withholding tax. With retroactive application to July 2021 and a broad interpretation of copyright law, multinational companies face significant compliance risks and potential exposure across software distribution, cloud services, and digital intermediation arrangements.

CC

Corrs Chambers Westgarth

Hilton: Part IVA, Alternative Postulates And The Evidence Problem

'Hilton International Australia Pty Ltd v Commissioner of Taxation (No 2) [2026] FCA 1325' examines Part IVA's treatment of alternative postulates and the critical role of evidence in tax benefit analysis. The Federal Court's decision establishes that multiple reasonable alternatives may exist, and that a Part IVA scheme cannot serve as a valid counterfactual to another Part IVA scheme.

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KordaMentha

Tax As A Governance Risk: What Australia’s Enforcement Shift Means For Boards

The most significant shift in Australian tax enforcement is not tax rates, but the convergence of transparency, enforcement and foreign investment scrutiny – elevating tax into a first‑order governance and reputational risk for boards.

CC

Corrs Chambers Westgarth

Don’t Let Australia’s R&D Tax Incentive Trigger Unintended US International Tax Cost Sharing Issues

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WilmerHale

Mid May Tax Update

PP

Pointon Partners

End of April Tax Update

PP

Pointon Partners

New Reportable Tax Positions Schedule Disclosure Requirements 2024

AM

Alvarez & Marsal

Mylan Australia Holding Pty Ltd V Commissioner Of Taxation – Part IVA Ruled Not To Apply To Debt Push-Down

AM

Alvarez & Marsal

Risk Assessing IP Planning…the Australian Experience

AM

Alvarez & Marsal

The benefits and pitfalls of royalty and interest payments in international tax planning

FA

Fortis Accounting Partners

Australian Federal Budget 2023-2024 - Key Tax Measures And Instant Insights

KG

K&L Gates LLP

Exposure draft legislation released regarding significant thin capitalisation changes

RA

RSM Australia

Financial Reporting Valuation Services

FC

FTI Consulting

Current Visa Processing Times: July 2026

Australia Immigration

IL

Interstaff Immigration Agency

Insights Into The State Of Commercial Property Market (Podcast)

Australia Real Estate

CP

Cathro & Partners

How Australia Prioritises Partner And Family Visa Processing From 25 July 2026

Australia Immigration

IL

Interstaff Immigration Agency

Australia Pauses Work And Holiday Visa Applications From 24 Countries

Australia Immigration

IL

Interstaff Immigration Agency

Podcast: Coffee with CGW – Get to know Vanessa Thompson

Australia Real Estate

CG

Cooper Grace Ward

A sharper focus on intangible assets

PCG 2021/D4 sets out the ATO's compliance approach to the taxation of international related party intangible arrangements.

MA

Moore Australia

Taxing the digital economy

The international tax rules are being reformed to cope with the increasing digitalisation of business.

PM

Pinsent Masons

Key considerations for investing in Australia – Tax

Each level of government in Australia imposes its own taxes – Federal, State and Territory, and Local Governments.

CG

Coleman Greig Lawyers

ATO Issues Draft Guidance On The Thin Capitalization Arm's Length Debt Test

The PCG will have effect from July 1, 2019.

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Duff and Phelps

Australia Court Rules In Favor Of Glencore In Transfer Pricing Case

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Duff and Phelps

Changes To Reporting Tax Uncertainties – AASB Interpretation 23

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Duff and Phelps

Simplified Transfer Pricing Record Keeping Options In Australia

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TMF Group BV

Glencore Triumphs Over ATO In Landmark Australian Transfer Pricing Case

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DLA Piper UK LLP

ATO Issues Draft Guidance On Thin Capitalization Arm's Length Debt Test

Da

Duff and Phelps

Transfer pricing annual review 2018 – Financier Worldwide

SF

Spruson & Ferguson

Taxation of entities with a significant digital presence in the EU

CB

Colin Biggers & Paisley

Overseas supply to Australian resellers - taxation of the suppliers

CB

Colin Biggers & Paisley

Multinational Enterprises Operating In Australia Should Be Vigilant About How They Are Meeting Their Tax Reporting Obligations

TG

TMF Group BV

The OECD multilateral instrument has widespread tax implications

CB

Colin Biggers & Paisley

Taxation of entities with a significant digital presence in the EU

Australian exporters and importers should review their outward and inward supply chains and transfer pricing arrangements.

CB

Colin Biggers & Paisley

Overseas supply to Australian resellers - taxation of the suppliers

How tax legislation aims to prevent erosion of domestic taxable profit through multinational supply chains - draft TD 2018/D1. .

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Colin Biggers & Paisley

Multinational Enterprises Operating In Australia Should Be Vigilant About How They Are Meeting Their Tax Reporting Obligations

New regulations for Transfer Pricing (TP), Country-by-Country (CbC) reporting and General Purpose Financial Statement (GPFS) reporting regimes impose a heavy compliance burden on multinational enterprises doing business in Australia.

TG

TMF Group BV

The OECD multilateral instrument has widespread tax implications

Treasury has released the Treasury Laws Amendment (OECD Multilateral Instrument) Bill 2018 to implement the convention.

CB

Colin Biggers & Paisley

Key cases that transformed the legal landscape in 2017 - and how they will impact your business

Australia Litigation

HR

Holding Redlich

Transfer pricing - the current landscape in Australia

The first set of mega transfer pricing disputes in Australia underscores some important practical considerations.

CU

Clayton Utz

More road signs needed at the intersection of international tax laws to avoid disputes

The ATO is doing a good job in trying to revisit how it delivers guidance to ensure it is provided on a timely basis.

CU

Clayton Utz

New measures on global tax avoidance – what the shipping industry should watch out for

We look at the tax measures that are on the horizon and consider how these new rules will impact the shipping industry.

Australia Transport

NR

Norton Rose Fulbright Australia

Australian Federal Budget 2016

This includes business tax and international tax measures and some of the personal tax measures in the Federal Budget.

Australia Government

NR

Norton Rose Fulbright Australia

Budget 2016/17 - Multinationals in the spotlight

Australia Government

CU

Clayton Utz

Foreign investors face new tax hurdle to get FIRB approval

CU

Clayton Utz

Flexing Of The Arm's Length Principle In Australia: The Chevron Transfer Pricing Case

WL

Withers LLP

The transfer pricing Chevron decision - funding, parental support, currency… and the experts

CU

Clayton Utz

Tax controversy insights

NR

Norton Rose Fulbright Australia

Building Confidence – A change in approach by the ATO

MA

Moore Australia

Simplified transfer pricing record-keeping requirements

MA

Moore Australia

End of calendar year: Transfer pricing, changing duty rates and other customs considerations

Australia International

HH

Hunt & Hunt

Transfer Pricing - the ATO reconstruction power in Taxation Ruling 2014/6

MA

Moore Australia

Tax controversy insights - inaugural survey

NR

Norton Rose Fulbright Australia

ATO draft guidance on transfer pricing

MA

Moore Australia

The ATO develops a sense of proportion to 'low-risk' taxpayers transfer pricing (TP) documentation

MA

Moore Australia

The ATO response to the IGT transfer pricing recommendations - make haste slowly

MA

Moore Australia

Moore Stephens comments on draft transfer pricing rulings and practice statements

MA

Moore Australia

Adsidui emptor or taxpayers beware - The implications of new guidance on transfer pricing documentation, reconstruction and penalties

CC

Corrs Chambers Westgarth

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JONES DAY PRESENTS®: Navigating Australia's Toughening Tax Controversy Landscape (Video)

JD

Jones Day

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