Big Four depth.
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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.
Central filing does not remove local Pillar Two obligations.
Ireland's Budget 2027 proposes to legislate the OECD side-by-side package, with new safe harbours, and cuts the capital gains tax rate to 31 per cent. Germany has ratified the agreement for exchanging GloBE information returns, South Africa has added a local declaration for groups that file the return elsewhere, and Mauritius's domestic minimum top-up tax now has transitional qualified status. Argentina has replaced its transfer pricing implementing resolutions, with much higher documentation thresholds and a safe harbour for low value-adding services, for tax years beginning on or after 1 October 2026. The European Commission is reported to be considering changes to its proposed CORE levy on large companies with EU operations, which would apply to EU subsidiaries and branches of Australian groups. In Australia, the Full Federal Court in Sunna has held that a gain taxed in the wrong year can still be taxed in the right one.
Read the brief →A Stage 2 governance rating depends on testing as committed.
The ATO's 2026 findings reports show that governance ratings can now be reduced where groups do not test their controls as they committed to. Belgium's Constitutional Court has kept alive the challenge to the UTPR, and Belgium has moved its first Pillar Two filing and notification deadlines to 31 October 2026. The OECD has released the full 2025 edition of the Model Tax Convention. Italy's Supreme Court has held that cutting a trademark royalty to support foreign subsidiaries was not arm's length, and the Federal Court has upheld a Part IVA determination including $173.3 million in assessable income on the pre-sale restructure of the Hilton Sydney.
Read the brief →The ATO's week: GILTI confirmed, independent review withdrawn, AI and reasonable care.
The ATO has confirmed that a US GILTI inclusion, as rewritten by the One Big Beautiful Bill Act, still does not count as foreign CFC taxation for Australia's hybrid mismatch rules. It has also withdrawn the large market independent review from 1 October and will consult in October on what reasonable care means when taxpayers use artificial intelligence. Brazil has extended its transitional Pillar Two safe harbour to 2027 and introduced a rule protecting substance-based incentives. The United States has enacted tariffs of up to 500 per cent on Russian goods and up to 100 per cent on goods from the largest buyers of Russian energy. The expanded foreign resident CGT rules commence on 1 October.
Read the brief →Pillar Two: a new return, new guidance and a peer review.
The Inclusive Framework has released a revised GloBE Information Return, new administrative guidance and the terms of a peer review of every country's Pillar Two legislation. The Federal Court has upheld a Part IVA determination adding $173 million to assessable income on a pre-sale hotel restructure, holding that the Commissioner can rely on more than one reasonable alternative. The expanded foreign resident CGT rules received Royal Assent on 15 September. Treasury has released exposure drafts on the R&D Tax Incentive, a new innovation CGT concession and electric vehicle FBT, with submissions closing 28 September.
Read the brief →
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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.
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