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Transfer Pricing Services for Multinational Businesses Operating in Australia.
Helping organisations manage international related party dealings with confidence.
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NCSGX Australia brings technical precision and commercial insight to every transfer pricing engagement, so your business stays compliant, protected, and strategically positioned.
How We Deliver Transfer Pricing Compliance
A structured, end-to-end advisory process built around your business and the ATO’s expectations.
Initial Assessment & Scoping
We begin by understanding your business structure, intercompany transaction profile, and current compliance position. This allows us to identify risk exposure, documentation gaps, and priority areas before any work commences.
Transfer Pricing Policy Design
Our advisors work with your team to develop or refine a transfer pricing policy that reflects the economic substance of your operations and aligns with the arm’s length principle across all relevant transaction categories.
Benchmarking & Economic Analysis
We conduct rigorous transfer pricing benchmarking using leading commercial databases to identify comparable market transactions and support your chosen pricing methodology with credible, defensible data.
Documentation Preparation
We prepare compliant Local Files, Master Files, and supporting analyses that meet ATO documentation standards, ensuring your international related party dealings are fully evidenced and audit-ready.
Reporting & Lodgement Support
Where applicable, we assist with Country-by-Country (CbC) reporting preparation and lodgement, as well as the completion of international dealings schedules within your Australian tax return.
Ongoing Advisory & Review
Transfer pricing is not a set-and-forget obligation. We provide ongoing support to review and update your documentation annually, respond to ATO queries, and advise on structural changes that may affect your intercompany pricing arrangements.
Our Transfer Pricing Services for Australian enterprises
- Transfer Pricing Policy Design & Review
- Transfer Pricing Documentation (Local File & Master File)
- Transfer Pricing Benchmarking & Economic Analysis
- International Related Party Dealings Advisory
- Country-by-Country (CbC) Reporting
- Advance Pricing Arrangements (APA)
- Intercompany Loan Pricing & Financial Transactions
- BEPS Risk Assessment & Consulting
- ATO Audit Defence & Dispute Support
- Ongoing Compliance Monitoring & Annual Updates
The Benefits of Partnering with NCSGX
Reduced Audit Risk
Our transfer pricing documentation is prepared to ATO standards, giving your organisation a defensible, audit-ready compliance position at all times.
Regulatory Confidence
We keep your intercompany pricing aligned with the latest ATO guidance and OECD Transfer Pricing Guidelines, so you stay ahead of regulatory change.
Pricing Certainty
Through Advance Pricing Arrangements and robust policy design, we help eliminate uncertainty around your most complex intercompany transactions.
End-to-End Advisory
From benchmarking and documentation through to CbC reporting and ATO dispute support, we manage every aspect of your transfer pricing obligations.
Commercially Aligned Advice
Our recommendations are grounded in your business reality, balancing technical compliance with the commercial objectives that drive your international operations.
BEPS-Ready Compliance
We help multinational groups navigate evolving BEPS requirements, ensuring your profit allocation structures reflect genuine economic substance.
Specialist Benchmarking
Our transfer pricing benchmarking analyses draw on leading global databases to produce comparable market evidence that supports your pricing methodology.
Trusted Long-Term Partnership
We work alongside your finance and tax teams as a consistent advisory partner, providing continuity, institutional knowledge, and proactive compliance support year after year.
Solving complex business challenges across industries, every day.
People Also Ask
What is transfer pricing and why does it matter in Australia?
Transfer pricing refers to the pricing of transactions between related entities within a multinational group. In Australia, the ATO requires these transactions to comply with the arm’s length principle. Non-compliance can result in significant audit adjustments, penalties, and reputational risk for multinational businesses operating across borders.
Who needs transfer pricing documentation in Australia?
Any Australian entity that has international related party dealings, including the provision of services, goods, intellectual property, or financial arrangements with overseas affiliates is required to maintain transfer pricing documentation that demonstrates compliance with ATO standards and the arm’s length principle.
What is Country-by-Country reporting and who must lodge it?
Country-by-Country (CbC) reporting is a mandatory ATO obligation for multinational groups with global annual revenue of AUD 1 billion or more. It requires disclosure of revenue, profit, tax paid, and economic activity across each jurisdiction where the group operates, supporting global tax transparency.
How does an Advance Pricing Arrangement reduce transfer pricing risk?
An Advance Pricing Arrangement (APA) is a formal agreement with the ATO that pre-approves your transfer pricing methodology for a defined period. It eliminates uncertainty around future audit adjustments and provides long-term compliance certainty for complex or high-value intercompany transactions.
What is transfer pricing benchmarking and why is it required?
Transfer pricing benchmarking involves analysing comparable market transactions or companies to establish an arm’s length price range for intercompany dealings. The ATO expects benchmarking to be conducted using credible, current data sources to support the pricing methodology applied in your transfer pricing documentation.
How does BEPS affect transfer pricing obligations for Australian businesses?
The OECD’s BEPS initiatives have significantly strengthened transfer pricing rules globally, including in Australia. Multinational groups must now ensure their profit allocation genuinely reflects economic substance and value creation. BEPS compliance requires updated documentation, transparent reporting, and pricing structures that withstand scrutiny from multiple tax authorities.