Transfer Pricing Accountant Sydney

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    We’ve been working with Rafal for the past two years, and I couldn’t be happier with his services. He’s incredibly reliable, always professional, and takes the time to explain things in detail. One of the best parts is that he speaks both Polish and English, which makes communication a breeze. Highly recommend him for anyone looking for an experienced and trustworthy accountant!

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Your Australian business pays a related overseas company for services.

Or an offshore entity charges your local company for software, management fees, stock, loans, royalties or intellectual property. The invoice may look ordinary, but the relationship behind it changes the tax question.

Would an unrelated business have paid that amount on those terms?

I’m Rafal Slowinski, Director of Tax Accounting Group Pty Ltd. I help business owners in Sydney review related-party international dealings before pricing, documents and the tax return position become difficult to defend.

Transfer pricing is not only a large multinational issue. Smaller groups can also face risk when money moves between connected entities across borders, and no one has properly explained why that price was used.

Rafal explaining financial concepts to a colleague using a laptop

The Person Reviewing The Related-Party Deal

Rafal Slowinski is a highly accomplished tax specialist and the Director of Tax Accounting Group Pty Ltd. He holds a degree in Accounting and Tax Law from the University of New South Wales, and his work has focused on helping Australian business owners make complex tax structures easier to understand.

He has partnered with more than 2,000 businesses, providing tailored accounting solutions and sophisticated, compliant tax minimisation strategies. His proactive approach focuses on identifying hidden efficiencies, safeguarding wealth and helping business owners solve serious financial and regulatory challenges.

For transfer pricing, I want to understand the deal behind the invoice.

Who provided the service? Who received the benefit? Was there a written agreement? How was the price chosen? Was the same service available from an unrelated supplier? Did the Australian business genuinely need it? Is the charge connected to goods, finance, management, intellectual property, staff, systems or something else?

Those questions help turn a related-party payment from a loose accounting entry into a position that can be explained.

Rafal presenting tax information on a whiteboard at Tax Accounting Group

The Invoice Is Not Enough

A related-party invoice can tell you the amount charged, but it does not always explain why the amount is commercially reasonable.

That is where many businesses get exposed.

A management fee may be charged each month without evidence of what was actually done. A related overseas supplier may sell goods to the Australian entity without any comparison to independent pricing. A loan may carry an interest rate that no one has benchmarked. A royalty may be paid for brand use, software or intellectual property, but the commercial basis may not be documented.

If the ATO asks why the Australian entity paid that amount, the answer should be more than “because the group company invoiced it.”

I help you identify what the payment is, what evidence supports it and where the pricing explanation may be weak.

Rafal discussing accounting services with a client in a modern office hallway

Transfer Pricing Advice for Cross-Border Groups

Transfer pricing advice for Sydney businesses may be needed when an Australian entity deals with a related overseas party.

That may include goods purchased from a related manufacturer, services charged by an offshore parent, management fees, licence fees, royalties, software charges, related-party loans, cost sharing, staff support, contractor arrangements or payments for intellectual property.

The issue is not automatically that the payment is wrong.

The issue is whether the business can show that the pricing has been considered and that the Australian tax position is not being shaped by a related-party amount that would not make sense between independent businesses.

As a transfer pricing accountant in Sydney, I help you review transactions from a tax and accounting perspective before they become a return, an audit question or an unexplained deduction.

Rafal reviewing financial documents and reading in Tax Accounting Group office

What Changes When The Parties Are Connected

Independent businesses usually negotiate from separate interests.

Related entities do not always behave that way. One company may accept a price because the group controls both sides. A fee may be set for convenience. A charge may be copied from another country. A loan may be created without the same documentation that a bank would expect. A service fee may be used because it has always been used.

That does not mean the arrangement is automatically wrong.

It does mean the transaction needs a clearer explanation.

I look at the commercial reason for the dealing, the benefit received by the Australian entity, the pricing method used, the documents available and whether the accounting records show the transaction in a way that supports the tax position.

Rafal explaining financial data to a client using a laptop in Tax Accounting Group office

Documents That Help Defend The Position

Transfer pricing is easier to discuss when the paperwork shows the commercial story.

Useful documents may include related-party agreements, invoices, service descriptions, loan terms, royalty agreements, pricing calculations, comparable supplier quotes, internal group policies, emails explaining the arrangement, financial statements and evidence showing the Australian entity received a genuine benefit.

Sometimes the best first step is to gather what already exists and see what is missing.

From there, I can help you understand whether the transaction is being described clearly, whether the Australian accounts support the payment and whether additional specialist transfer pricing documentation may be required.

If the arrangement is complex or high-value, it may also need support from a specialist transfer pricing economist or legal adviser. I can help coordinate the tax and accounting side so the business owner is not left trying to interpret the issue alone.

Rafal assisting a colleague with accounting work at a computer

Before The Charge Becomes A Year-End Deduction

A related-party charge should be reviewed before it is simply treated as a deduction in the Australian accounts.

That is especially important when the amount is large, recurring, unusual, connected to intellectual property or paid to a low-tax country. It is also important when the same charge affects multiple years.

If the pricing has not been considered, the year-end tax return may carry a risk that could have been addressed earlier.

I can review the transaction, identify what needs support and explain what should be clarified before the charge flows into the return.

Rafal from Tax Accounting Group consulting a client at a desk with a laptop

Ask About The Related-Party Payment Itself

If you need transfer pricing advice in Sydney, start with the payment, invoice, contract or group arrangement that feels difficult to explain.

Send Rafal the related-party detail you have, and he can help you work out what the payment is, what evidence supports it and whether the pricing position needs stronger tax support.

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    Frequently Asked Questions

    • Transfer pricing may be relevant when an Australian business deals with a related overseas party, such as a parent company, subsidiary, associated company or commonly controlled entity. The issue is whether the price reflects a commercial outcome that could be explained between independent parties.

    • Management fees, service charges, royalties, software fees, related-party loans, interest, stock purchases, cost-sharing arrangements, intellectual property payments and support charges can all raise transfer pricing questions.

    • No. Large groups face more obvious scrutiny, but smaller cross-border businesses can still have transfer pricing issues if related-party transactions are material, poorly documented or difficult to explain.

    • Bring the invoice, agreement, service description, loan terms, royalty arrangement, pricing calculation, group policy or any document showing why the amount was charged and what benefit the Australian business received.