Episode 120: Increased scrutiny, higher stakes: Inside Australia’s TP enforcement shift

Kristina Novak (Principal in PwC’s US Transfer Pricing Practice) is joined by Nick Houseman, PwC Australia’s Transfer Pricing Leader, during PwC’s Global Transfer Pricing, Customs and Indirect Tax Conference in Prague. Kristina and Nick discuss Australia’s tax and transfer pricing enforcement landscape, shaped by the Australian Taxation Office’s (ATO) “justified trust” approach, robust audit programs, and whole-of-code review model. They explore the implications of the High Court’s PepsiCo decision and its broader relevance for royalty withholding and related-party arrangements. The conversation also addresses audit focus areas including distributor returns, inbound financing, and DEMPE-related challenges. Nick outlines key compliance tools such as the reportable tax position schedule and trends in bilateral APAs. They conclude with practical guidance for multinationals on navigating Australia’s new public country-by-country reporting regime and maintaining consistency across disclosures in an increasingly transparent tax environment.