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Direct access to senior expertise. No layers, no juniors: every engagement is led personally by Neil, 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.
Corporate Tax
Optimise your global position, manage effective tax rates and keep compliance and governance defensible across jurisdictions.
Transfer Pricing
Defensible policies aligned with OECD guidelines. Benchmarking and Subdivision 815-B compliant global documentation.
International Tax
BEPS, anti-hybrids, thin capitalisation and cross-border structuring with confidence and clarity.
Governance & Disputes
Justified Trust readiness, controls testing, and steady hands through ATO reviews, audits and objections.
Also on the bench
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 thin capitalisation rules have produced their first full year of numbers.
Debt deductions disallowed reached about $9.0 billion in 2023-24 against about $3.4 billion the year before, and the Board of Taxation's review meets peak bodies today. Parliament has created a charge on large digital platforms at 2.75 per cent of Australian digital advertising revenue, administered by the Commissioner and applying from 2025-26. The ATO is considering whether MT 2008/1 and MT 2008/2 need updating for the use of artificial intelligence. The OECD has published the comments on its rewrite of the intra-group services guidance.
Read the brief →The law barely moved this week; the machinery around it did.
The ATO will terminate the large market independent review from 30 September 2026 and is consulting on a final offer arbitration pilot for protracted disputes. The first exchange of Pillar Two GloBE Information Returns between tax administrations is expected towards the end of September. A five release transparency timetable will culminate in the first public country by country reports in late October. Each of these developments changes how a position is tested rather than what the position is.
Read the brief →What is being measured is changing, not the rate.
Australia has introduced Bills for a proposed 2.5 per cent non-deductible charge on certain large digital platform groups, applying from the 2025-26 financial year if enacted. A separate foreign resident CGT Bill would broaden the concept of real property and replace point-in-time principal asset testing with a 365-day look-back. At the multilateral level, a new United Nations Co-Lead's Draft on cross-border services proposes nexus and allocation rules that do not rely on permanent establishment concepts. Meanwhile, recent Pillar Two announcements show registration, notification, filing, payment, penalty and interest relief increasingly moving on separate tracks.
Read the brief →The Pillar Two exposure is moving from the number to the filing.
The ATO turns to lodgment mechanics and confirms that GloBE joint ventures sit inside the Australian filing perimeter; Qatar and the United Arab Emirates both put hard registration dates on Pillar Two, and neither depends on whether any top-up tax is payable; and mandatory binding arbitration opens on the Australia to Canada corridor, reaching back to cases presented from December 2019.
Read the brief →
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"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.
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