In Episode 7 of Tax Chats: International Tax (101), Danielle delves further into the extensive world of Transfer Pricing albeit with a focus on Outbound Issues. 

This episode provides a brief exploration of Transfer Pricing Outbound Issues, emphasizing key considerations, especially for foreign subsidiaries of Australian companies.

Tax Chats (International Tax 101) is a ten-part series where Danielle provides quick and practical updates on topical international tax issues. These updates are designed to help you (or your clients) identify and understand potential international tax and transfer pricing risks before any ATO review activity. 

If you have any questions in relation to international tax and transfer pricing, please contact Danielle by emailing [email protected].

Key takeaways:

1. Transfer pricing / Tax planning – a Transfer Pricing Policy will govern a taxpayers operation/transaction flow for the offshore subsidiary, so it is important to understand the tax outcomes and repatriation of funds under the various operating models.

2. Controlled Foreign Company (CFC) – rules will also be relevant when devising a transfer pricing policy, as some operating models may be more susceptible to attribution under Australia’s CFC rules (which can be both good or bad depending on the taxpayer).

3. International Dealings Schedule (IDS) – All entities with outbound operations should be preparing an IDS, alongside their ITR, and ensuring these disclosures are completed correctly.

Danielle Sherwin

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International Tax 101: Transfer pricing - Outbound Issues | Episode 7

Danielle is a Principal in the Tax Services division in the Sydney office. 

Danielle specialises in international tax, with a focus on transfer pricing and international tax. She assists her clients with their international tax planning and transfer pricing needs, ranging from Significant Global Entities (SGE) assessment, Country-by-Country (CBC) reporting, transfer pricing planning and advisory to transfer pricing compliance and documentation. 

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