Transfer Pricing in life sciences: Adapting to the new world

Transfer Pricing in life sciences: Guidance

Watch a short snapshot video from KPMG Partner Jeremy Capes where he provides an update on recent developments in the Australian transfer pricing landscape for the life sciences industry, as well as his full presentation in the recording of our Life Sciences Tax Update webinar held on 28 August 2019.

Jeremy Capes

Partner, International Tax Advisory – Transfer Pricing

KPMG Australia


The Australian Tax Office (ATO) is currently actively focused on the Pharmaceuticals and Life Sciences industry. As an industry dominated by multinational organisations and cross border value chains, international tax issues and transfer pricing are at the heart of the ATO’s focus.

As many will recall, the most recent movement began in 2015 with the Senate inquiry into Multinational Tax Avoidance for which many Pharmaceuticals and Life science companies were called to appear. The ATO feels compelled to review the industry given the political and public interest in multinationals corporations ‘paying their fair share of tax’.

The ATO has been otherwise buoyed by the BEPS movement that has occurred in parallel, new laws in Australia and the fact that the taxpayer bears the onus of proof. This means that more than ever, taxpayers should consider transfer pricing when:

  1. Entering arrangements, by considering how third parties would enter similar arrangements ensuring the arrangements make commercial sense
  2. Documenting the arrangements to ensure robust transfer pricing analysis is undertaken and full supporting files are maintained
  3. Sustaining positions as time passes, ensuring appropriate governance frameworks and processes exist to review/update the transfer pricing or the arrangements as and when required

With a focus on the industry and the Justified Trust program in full flight, ATO engagement is not a case of ‘if’ but ‘when’ for many taxpayers in the Pharmaceuticals and Life sciences industry and active management and preparation is the best strategy for navigating ATO inquiries.

Presentation slides

View a copy of the slide presentation from the webinar.

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