Tax for Corporates

Tax for Corporates

We have a highly skilled specialist tax team working with multinational corporations and Australian subsidiaries of overseas companies, as well as Australian and Asia Pacific firms across the wholesale sector.

Navigating the detail of tax can be a daunting task for businesses and finance teams, particularly for companies with complex transactions, structures and workforces. We’ll help you identify and manage tax risks, maximise opportunities and minimise exposure, take realistic tax positions and ensure compliance with all ATO requirements. 

We have a highly skilled specialist tax teams working with multinational corporations and Australian subsidiaries of overseas companies, as well as Australian and Asia Pacific firms of all sizes.  

Our significant involvement in industry and a high level of involvement in reforms, both legislative and administrative, means we are actively involved and across all current tax issues that impact business.  

We are closely involved in consultative processes, making submissions to Treasury and/or the ATO and have extensive experience managing successful ATO reviews including Combined Assurance Reviews (CARs), Streamlined Assurance Reviews (STARs) and ATO top 20 and top 100 reviews.  

Our team can provide end-to-end solutions across: 

  • corporate & International tax advisory 
  • Country by Country reporting 
  • employment taxes (PAYG, FBT, superannuation and payroll) 
  • expatriate taxes 
  • FATCA / CRS 
  • fuel tax credits 
  • fund tax advisory 
  • Government grant assistance 
  • global workforce mobility services 
  • GST and indirect taxes 
  • tax due diligence 
  • transfer pricing 
  • tax structuring 
  • tax effect accounting  
  • tax governance implementation and review 
  • tax controversy, dispute, review and audits 
  • tax compliance automation 
  • research and development tax incentive 
  • remuneration and benefits (share schemes) 
  • State taxes (Stamp Duty, Land Tax, GAIC).

Corporate taxes

As a leading advisory firm, we provide advice, compliance and specialist tax services to clients of all sizes across sectors, operating both domestically and internationally. 

In addition to their compliance needs, these clients regularly require advice on all manner of tax issues, including:

  • tax consolidation ACA and AF calculations 
  • tax loss recoupment and relevant loss testing conditions
  • tax effect accounting
  • due diligence matters for taxation purposes
  • thin capitalisation issues
  • CFC issues and foreign hybrid issues relating to international investments
  • foreign exchange transactions
  • CGT liabilities and available concessions
  • Division 7A management
  • Division 6C, MIT, AMIT and FATCA related issues
  • Division 250 issues
  • structuring of investments and dispositions, both national and international
  • withholding tax matters
  • GST
  • State taxes, including duties and land tax
  • transfer pricing advisory & compliance
  • global workforce mobility services.

Specialist tax

Technical involvement on industry matters

Our significant involvement in industry, and a high level of involvement in reforms (whether legislative or administrative) mandates an active involvement in current tax issues that impact business. Various members of our team have, and continue to be, closely involved in consultative processes, making submissions to Treasury and/or the ATO on relevant matters, and various draft tax rulings with a potential industry impact.

Subject matter experts were recently involved in a review of the ATOs Tax Management Framework and training programs as part of industry consultation on the implementation. Our tax team is also actively involved in relevant industry tax forums, including several subgroups of the National Tax Liaison Group, and representative industry bodies.

In terms of dealings with the tax authorities, we have extensive experience. Whether managing an ATO risk review, or audit, requesting a private ruling or involvement in a tax dispute, we have outstanding credentials and experience in such matters. 

Due to the breadth of our client base, we have and are assisting clients to manage a range of ATO reviews including Combined Assurance Reviews (CARs), Streamlined Assurance Reviews (STARs) and ATO top 20 and top 100 reviews.

R&D tax incentives

SW has a dedicated national R&D team with in-depth experience of working with the ATO and other government departments over many years, across many sectors. Our approach cuts through complexity to maximise success and services include: ​

  • identifying and scoping eligible R&D activities ​
  • preparing the R&D Application for registration of R&D activities ​
  • calculating eligible R&D expenditure and preparing the R&D Tax Schedule to claim the benefit ​
  • assisting with R&D governance and documentation processes ​
  • conducting R&D training and governance workshops.​

Transfer pricing

In our fast-paced world, our experienced team can ensure you maximise your transfer pricing opportunities, while also ensuring that you meet the ever-evolving compliance requirements.

What is Transfer pricing (TP)​When two entities that are part of the same group undertake any type of cross-border trade with each other, they need to establish a price for that transaction, as if they were unrelated parties and the transaction was a ‘real’ negotiation, conducted at ‘arms length’. The price that one entity then pays is referred to as the ‘transfer price’.​ TP rules and regulations aim to ensure that an unfair income tax outcome has not been derived.​

The changing landscape of TP ​

The TP landscape has been constantly evolving over the last decade, with stricter regulation and governance introduced in Australia as well as globally. As part of this process, our team work closely with clients to help identify ways in which more cost-effective set-ups for international transactions can be put in place.  ​

The COVID-19 pandemic has also made a significant impact on many businesses that are facing a change in their global supply chains. These changes have also driven TP to become an integral part in supporting business leaders to make key commercial decisions that will ultimately support business growth / changes, while also mitigating compliance risks.​

Wider coverage of TP​

TP used to focus narrowly on whether the ‘pricing’ for transactions between International Related Parties (IRPs) is arm's length. Nowadays, TP is no longer limited to pricing but places greater emphasis on ‘conditions’ in connection with commercial or financial relations between IRPs.  In other words, there is greater focus on the commerciality of the arrangement and terms agreed upon between the parties. This could potentially result in a transaction being 'reconstructed' from where it actually stands.​

With the wider coverage and increased complexity, taxpayers involving IRP dealings are expected to ‘self-assess’ and prove their dealings conform with the arm's length principle.​

TP in Australia​

Australia is highly dependent on corporate income tax compared to the other OECD countries. As multinational enterprises (MNEs) involving IRP dealings are a key contributor to Australia's corporate income tax base, Australian Taxation Office (ATO) places a continuous focus on TP.​

TP in Australia could be subject to an ATO review for up to 7 years. As evidenced by significant Australian litigation cases recently – ChevronGlencore and Singtel, the risk of TP adjustments and penalties could be substantial.​

Managing TP properly not only helps enhance tax certainty, but also enables businesses to direct time and resources more efficiently on business commitments (not on ATO reviews).​

TP around the globe​

TP administration has been heightening globally with the implementation of OECD Base Erosion and Profit Shifting (BEPS) initiatives since 2013. ​

While MNEs’ business and financial information is under wider and potentially public scrutiny through Country-by-Country Reporting, they now face new opportunities arising from OECD’s ‘Two-Pillar’ international tax reform project (BEPS 2.0), where TP will play a key part in substantiating whether the profit allocated in different jurisdictions aligns with value creation in the global supply chain – a particularly relevant consideration for MNEs under restructuring and value chain transformation.​

Our practical and proactive, cost-effective solutions:

TP in Base Erosion & Profit Shifting (BEPS)

  • Analysis of commercial activities, intangibles and profit allocation to support business value chain structuring / transformation​
  • Collaborating with our international offices to help businesses respond to BEPS 2.0 changes​
  • Country-by-country reporting (via SW in-house software)​

Operational TP planning

Design TP policies and assistance with policy implementation (including system and agreement reviews) to help businesses achieve their inbound / outbound commercial strategies​

Advance pricing arrangement (APA)

Assistance with unilateral and bilateral APAs including developing strategies for the timely negotiation and cost-effective implementation​

Continuous learning opportunities

  • Client specific tax and TP training ​
  • English & Mandarin tax update seminars/webinars​
  • Insights from ATO Working group​
  • Ongoing tax and TP alerts

TP compliance

  • s815 ‘audit-ready’ TP documentation for Australian  subsidiaries/branches​
  • Globalised documentation for Australian parents​
  • Assistance with International Dealings Schedule, Reportable Tax Position, Practical Compliance Guideline​

Whether your team is experienced and requires an independent view, or whether you are just starting out, or your business is changing and growing, our team is well placed to assist you. 

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