Transfer Pricing 2025

AUSTRALIA Law and Practice Contributed by: Michael Clough, Jerome Tse, Judith Taylor and Scott Heezen, King & Wood Mallesons

King & Wood Mallesons (KWM) is recognised as one of the world’s most innovative top-tier international law firms and offers access to a global platform, with a team of over 3,700 law - yers in 27 locations around the world. KWM Tax has the most experienced team in the Austral - ian legal services market, with the strength of 14 tax partners and over 60 team members. It has led seminal tax cases on anti-avoidance (BHP and RCI) and transfer pricing (Chevron and Glencore), and key cases on State taxes

(Bupa, Vicinity). The tax disputes team acts only for taxpayers in all tribunals and courts through - out Australia. KWM Tax advises multinationals on transfer pricing risks for transactions and structures, using experience gained in running leading Australian transfer pricing cases. It ad - vises and assists taxpayers with transactions and disputes involving global, regional and local transfer pricing laws; drafts transfer pricing poli - cies; and prepares transfer pricing documenta - tion for high-value and high-profile transactions.

Authors

Michael Clough is a partner in King & Wood Mallesons’ Melbourne office and recently its chairman in Australia. He specialises in tax issues that arise in international

Jerome Tse is a tax partner at King & Wood Mallesons specialising in transfer pricing, and tax controversy and litigation. Jerome regularly advises clients on all aspects of

transactions and structures. Chambers Global has recognised Michael’s “leading tax disputes practices with significant experience in the Supreme, Federal and High Courts acting for many of the largest corporations in Australia in high-profile cases” . He advises some of the largest global corporations and his work includes all aspects of tax audits and litigation such as negotiations and actions in relation to the collection of tax, access to premises, production of documents and tax appeals generally.

transfer pricing, including as part of global M&A transactions, in an advisory capacity and in tax disputes and litigation. This includes several matters involving the transfer pricing aspects of intangibles and IP migrations. He has also been involved in seminal Australian transfer pricing cases, including Chevron and Glencore, and presents transfer pricing papers internationally, including at the recent 2025 Canadian Tax Foundation conference and American Bar Association tax conferences.

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