Most clients come to us at one of these moments.
If one of these describes where you are, a 30-minute call will tell you what the decision is and what it is worth getting right.
Entering Australia
Before your first intercompany invoice in Australia, we set the pricing model and the documentation so it holds up at review.
See International Tax and Transfer Pricing → 02DisputesAn ATO letter has arrived
When an ATO letter arrives, we decide with you what to give, what to defend and in what order.
See Governance and Disputes → 03Pillar TwoYour first Pillar Two year
In your first Pillar Two year, we map who files what, where, and which safe harbours you can rely on.
See Pillar Two → 04R&D · TPR&D for a foreign parent
When a foreign parent wants R&D done in Australia, we structure it so the claim and the intercompany charge both stand up.
See Transfer Pricing → 05Corporate · International · TP · LegalOffshore expansion, moving IP or restructuring
Before you expand offshore, move IP or restructure, we map what each step triggers in Australia, across tax, transfer pricing and the legal documents.
See Corporate Tax and International Tax → 06GovernanceYour Top 1000 review is coming
Before your Top 1000 review, we test whether your tax governance will reach the Stage 2 rating the ATO requires for high assurance.
See Governance and Disputes →Raising capital, scaling or heading to IPO? Twice a year, we tell your board which tax triggers are coming next.
See the Lifecycle Diagnostic →Big Four depth.
Boutique attention.
Direct access to senior expertise. Every engagement is led by Neil, on a fixed fee, from day one.
Pillar Two: from model to mandate
The global minimum tax is now a reality. Whether you are assessing exposure, implementing compliance frameworks or optimising your structure, you need guidance that bridges policy and practice. GIR, QDMTT, Transitional Safe Harbour, GloBE calculations, multi-jurisdiction filings.
Call us whenyour first filing year is coming up, or a jurisdiction in your group brings in a top-up tax.
Discuss your Pillar Two position →Corporate Tax
Optimise your global position, manage effective tax rates and keep compliance and governance defensible across jurisdictions.
Call us whenyou are restructuring, acquiring, or changing how the group is funded.
Transfer Pricing
Defensible policies aligned with OECD guidelines. Benchmarking and Subdivision 815-B compliant global documentation.
Call us whenyou are setting up a new intercompany arrangement, or the business has changed since your last Local File.
International Tax
BEPS, anti-hybrids, thin capitalisation and cross-border structuring with confidence and clarity.
Call us whenyou are entering Australia, paying royalties or interest offshore, or moving people across borders.
Governance & Disputes
Justified Trust readiness, controls testing, and steady hands through ATO reviews, audits and objections.
Call us whenan ATO letter arrives, or your Top 1000 combined assurance review is coming up.
Also on the bench
What you can hold us to.
Five commitments that apply to every engagement, whatever its size.
-
Fixed fees, set by what is at stake
We cost the work properly. The fee reflects the decision you face, not the hours.
-
Partner-led
Neil leads every engagement and reviews all work before it reaches you.
-
Clear commitments
Scope, timetable and fee are agreed in writing. If our work falls short of the agreed scope, we finish it at no extra cost.
-
No promised outcomes
No adviser controls what the ATO decides. We tell you where your position is strong, where it is weak, and what would change it.
-
We talk it through
We walk you through every proposal before you sign.
Don't take our word for it.
Run your own numbers.
Five calculators built by the practice. This one below is live on this page; go ahead and use it.
TP Risk Heatmap
LiveDrop in your CbCR file, get an instant risk profile. 100% in-browser; nothing is uploaded.
Intangible Value Risk
LiveIntangibles arrangements mapped against ATO risk-zone guidance.
Digital Services Tax
LiveDST exposure under Pillar One and local regimes across your footprint.
PE Assessment
In buildPermanent establishment risk from your current activities and presence.
Pereira Consulting proprietary tools · Indicative only, not advice
Your company won't stay at one stage. Neither should your adviser.
From the founders' agreement to the prospectus and every trigger in between: one tax partner who orchestrates the lawyers, auditors and corporate finance advisers around you.
The Lifecycle Diagnostic
The Strategic Brief.
A weekly brief on the tax developments that matter to multinationals operating into and out of Australia.
The first Public CBC reports are out, and Australia consults on the side-by-side safe harbour.
The ATO published the first Public CBC reports on 12 November, covering 382 groups, mainly with a 30 June year end; most 31 December groups will follow in the next release. Treasury has released draft amendments that would add the side-by-side and ultimate parent entity safe harbours to Australia's minimum tax rules, with comments due by 26 November. Kenya has extended its first top-up tax notification to 30 November, Belgium's extended Pillar Two filing date of 16 November falls on Monday, and the ATO has issued a draft PCG on back-to-back CGT rollovers and Part IVA.
Read the brief →The High Court rules on Part IVA and payroll tax, while Pillar Two filing dates move again.
Belgium has published its later top-up tax return deadline, and Qatar has extended Pillar Two registration to 31 January 2027. Oman has added criminal penalties to its top-up tax law, and Singapore has updated its Pillar Two guidance. The OECD reports record dispute closures for 2025. In Australia, the High Court decided two major cases on 4 November: Merchant on Part IVA and dividend stripping, and Uber on payroll tax.
Read the brief →Pillar Two deadlines keep moving, and the evidence prepared at the time keeps deciding cases.
Belgium has adopted a law moving its domestic top-up tax return to 15 months after year end, and the UK and Ireland are moving to legislate the OECD side-by-side package. Singapore is offering a one-off waiver of its transfer pricing surcharge for groups that correct how they treated share-based compensation. In Australia, the Tax Reform No 4 Bill redesigns the R&D tax incentive, and the Tax Reform No 3 Bill has passed the House.
Read the brief →The side-by-side package reaches domestic law, and the ATO sets out its Part IVA view.
Ireland and Sweden have introduced bills to implement the OECD side-by-side package, and Uruguay has issued its domestic top-up tax regulations. A Ugandan tribunal has rejected a royalty to an IP owner that did not perform the DEMPE functions. In Australia, the ATO has set out its view on Part IVA alternative postulates after Hilton and Hicks, and public country-by-country reports for calendar year 2025 are deferred to 29 January 2027.
Read the brief →
The depth of a Big Four specialist. The attention of one adviser.
"Every engagement is led directly by me: no handing off to junior staff and no surprise fees."
My experience combining deep technical expertise with a genuine investment in understanding my clients and their operations allows me to identify value-add opportunities that tax optimise their business, bring forward savings and realise synergies.
Discuss your position with Neil directly.
A 30-minute scoping call costs nothing. You will leave knowing what the decision is and what it is worth getting right.