How BDO can help

Our Transfer Pricing team helps groups navigate this global transfer pricing environment. Aided by dedicated transfer pricing practitioners around the BDO network, we provide a range of planning, compliance, audit defence and benchmarking services. We work with your team to develop transfer pricing policies that are defensible, flexible and in line with your overall tax planning strategies.

We can help you with:

• Preparing transfer pricing documents in accordance with the new Australian self-assessment regime. This addresses the ATO’s five key questions on transfer pricing and allows the taxpayer to achieve a reasonably arguable position (RAP) in respect of filing their income tax return to minimise potential tax penalties.
• Assisting with the preparation and review of International Dealing Schedule (IDS) disclosures.
• Working holistically to understand the future strategy of your business and to design an optimal transfer pricing structure based on their value chain and the location of key operational personnel/assets/risks in the business. Substance is key to this work given the Australian reconstruction rules and the new regulations from the OECD on intellectual property.
• Assisting to respond to an ATO risk review/audit including strategy advice, drafting letters and meeting with the ATO.
• Obtaining an Advance Pricing Agreement (APA) where clients would like certainty on transfer pricing matters. This can be unilateral (just with the ATO), or bilateral (with the ATO and a foreign jurisdiction).
• Helping groups with A$1 billion to prepare to comply with new BEPS rules applying to accounting periods commencing after 1 January 2016. We can help clients consider upfront the impact of BEPS on internal transfer pricing risks and how these may be addressed. We can also assist with BEPS compliance in preparing a country by country report, master file and Australian local file.