When faced with managing complex transfer pricing related controversy matters with the Australian Taxation Office (ATO) and other major taxation authorities, multi-national organisations must solve a network of challenging issues. Navigating these requires expert advice and depth of experience to assist with the most complex of transfer pricing issues and challenges. MinterEllison's Transfer Pricing multi-disciplinary practice is comprised of lawyers, economists, Chartered Financial Analysts (CFAs) and past ATO employees to offer clients expert and precise transfer pricing solutions across the full spectrum and lifecycle of business structures.

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Integrated tax controversy and transfer pricing

Unified with our leading Tax Controversy practice, MinterEllison's Transfer Pricing practice provides strategic advice on ATO audits, risk reviews, settlements, litigation, negotiating bilateral and unilateral Advance Pricing Arrangements (APAs) and obtaining double tax relief under the Mutual Agreement Procedure (MAP) article in Australia's tax treaties. We manage collateral tax issues related to permanent establishment profit attribution, thin capitalisation, debt/equity provisions and Australia's general anti-avoidance rules, including Part IVA, the Diverted Profits Tax (DPT) and Multinational Anti-Avoidance Law (MAAL).

Our Transfer Pricing practice teams work closely with MinterEllison's Corporate Tax and Capital Markets teams to provide solutions across the full spectrum and lifecycle of multinational business structures.

Knowledge and expertise

Through our specialist skills, understanding of risk governance and deep sector knowledge, we offer clients insights to identify potential tax risks and achieve effective outcomes.

Multi-disciplinary expertise with global focus

We have the depth of experience to assist with the most complex of transfer pricing issues and challenges, including: