Transfer Pricing

The Australian Government views transfer pricing as a significant risk to Australia’s tax revenues.

It has responded by strengthened transfer pricing rules, increased penalties, and new anti-avoidance provisions such as Multinational Anti-Avoidance Law (MAAL) and Diverted Profits Tax (DPT). 

As a result transfer pricing is an increasingly important issue for multinationals in designing their supply chains, cross border transactions, and managing their tax risks.

Greenwoods & Herbert Smith Freehills’ transfer pricing team can assist you with optimising your transfer pricing positions including:

  • Transfer pricing planning and policy development;
  • Transfer pricing documentation and benchmarking;
  • Analysis for Managed Investment Trusts non-arm’s length income rule;
  • Negotiation of Advanced Pricing Agreements;
  • Assisting with Australian Taxation Office interactions and audits;
  • Assisting with resolving transfer pricing disputes and litigation; and
  • Country by Country reporting.

Our transfer pricing team has extensive experience across a range of industries.

Our transfer pricing team has deep international tax knowledge and so can also advise on the international tax aspects of cross border transactions.

On major transactions and disputes (including litigation) we work seamlessly with our Herbert Smith Freehills colleagues.

Head of Transfer Pricing

David Bond

David Bond is a Partner in Greenwoods & Herbert Smith Freehills’ Perth office and the National Transfer Pricing Leader.

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Transfer Pricing team

Julian Pinson



Kristy-Lee Smith