Tax Controversy & Transfer Pricing

Our tax controversy and transfer pricing experts combine deep economic expertise with practical, litigation-ready insights. We have extensive experience across a wide range of Australian tax controversy and transfer pricing matters and support clients at every stage of the dispute process, from audit and advisory through expert reports and testimony.

Brattle experts have testified in major jurisdictions, including the US, Canada, and the UK, bringing globally informed perspectives to Australian disputes. We also work closely with leading industry and technical specialists  – including experts in credit ratings, debt issuance, industry dynamics, and market structure – to deliver rigorous, defensible analyses that align with legal strategy and withstand scrutiny.

Core Capabilities:

• Transfer pricing
• Valuation of financial assets, intangible property, and securities
• Debt/equity characterization
• Economic substance/business purpose
• Financial instruments and markets
• Intercompany loan pricing
• Substance over form
• Structured finance