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Craig Silverwood

he/himPartner
Head of Transfer Pricing APAC*
APAC transfer pricing disputes are among the biggest risks multinationals face. DLA Piper resolves them with a global network of economists and tax lawyers.
— Craig Silverwood
Melbourne
*not an Australian legal practitioner
About

Craig leads DLA Piper's transfer pricing team in Australia and across Asia Pacific. With more than 25 years' experience, he advises multinational groups on transfer pricing strategy, audits, reviews and disputes involving the Australian Taxation Office and revenue authorities throughout the region. He has negotiated more than 25 advance pricing arrangements (APAs), including bilateral APAs, and has helped clients secure tax certainty and relief from double taxation through the mutual agreement procedure (MAP) provisions in Australia's tax treaties.

Craig established and led Australia's first dedicated transfer pricing controversy practice within a large law firm. Before joining DLA Piper, he gained 17 years' transfer pricing experience in the Big Four and as an economist with the Australian Taxation Office.

Drawing on his experience with a revenue authority and his extensive controversy background, Craig helps clients prevent disputes before they arise. He works closely with tax and legal teams to develop sustainable operating models, intellectual property structures and supply chains that produce defensible arm's length outcomes.

Craig advises multinational businesses across a range of sectors, including AI, data centres, technology, energy and resources, automotive, consumer goods and retail, defence and financial services.

Areas of FocusTransfer Pricing and ValuationInternational Tax and StructuringTax Controversy and DisputesTransactional TaxTechnologyEnergy and Natural ResourcesPrivate EquityInfrastructure, Construction and TransportConsumer Goods, Food and RetailArtificial Intelligence and Data AnalyticsData CentersIndustrialsAutomotiveAerospace and DefenseFinancial Services

EXPERIENCE

  • Defended the arm's length nature of AI and data centre charges and the associated operating model, including defending against revenue authority permanent establishment postulation and profit attribution hypotheses.*
  • Defended against the ATO's application of the transfer pricing reconstruction rules on a significant intellectual property migration matter.*
  • Led transfer pricing controversy matters through ATO review, audit, settlement and mutual agreement procedure, including multi-country MAP involving Australia with Thailand, the United States, India, Switzerland and Japan, and subsequent bilateral advance pricing arrangement negotiations.*
  • Successfully defended a client's Multinational Anti-Avoidance Law and Diverted Profits Tax position that was subjected to a detailed ATO review.*
  • Designed and implemented an intellectual property and distribution framework for a large multinational consumer products group, including advance pricing arrangement support for an Australia and New Zealand restructure.*
  • Advised on the international tax and transfer pricing aspects of cross-border M&A and private equity transactions, both pre- and post-acquisition, including intellectual property migration and supply chain redesign.*
  • Managed Foreign Investment Review Board tax conditions relating to regulatory review of shareholder debt arrangements and post-merger supply chain integrations.*
  • Advised a global automotive group on transfer pricing and TOFA audit defence, mutual agreement procedure and an Australia and Japan bilateral advance pricing arrangement.*
  • Advised a mining and mineral processing group on bilateral advance pricing arrangement and ATO dispute issues, including commodity pricing, integrated supply chain analysis and DEMPE related to intellectual property.*
  • Advised an energy major on transfer pricing audit defence and settlement, including upstream LNG and petroleum pricing and related party services.*
  • Advised on a bilateral advance pricing arrangement and Australian business restructure for a United States defence-related intangibles business.*
  • Advised a privately owned Australian retail group on international store and franchise expansion and the establishment of a Singapore supply chain and intellectual property principal entity, including defence of those arrangements in an ATO transfer pricing audit.*
  • Advised an ASX-listed Australian retail group on transfer pricing licensing, visual merchandising and supply arrangements for new stores in New Zealand and South Africa, including an advance pricing arrangement with the ATO.*
  • Advised a global cosmetics and personal care group on the migration of product and store intellectual property and marketing functions to a European regional hub and intellectual property holding company.*

*Denotes experience gained at previous firm.

Education
  • Juris Doctor (in progress), University of Canberra, targeted completion 2026
  • Master of Taxation, UNSW, 2003
  • Bachelor of Economics, La Trobe University, 2000
  • Bachelor of Health Science, La Trobe University, 1997

AWARDS AND RECOGNITION

  • Led the practice recognised as Transfer Pricing Firm of the Year, International Tax Review, 2018, 2019 and 2020
  • Highly Regarded Practitioner, ITR World Tax and Transfer Pricing

Publications and media

  • Articles for Bloomberg BNA Tax Management Transfer Pricing Report
  • ATO consultation submissions and published responses
  • Tax Institute conference papers and training materials
  • Thought leadership on Pillar Two and transfer pricing intersections, DEMPE, ATO audit strategy, mutual agreement procedure, and permanent establishment profit attribution for data centre operations

Seminars

  • Regular presenter, Silicon Valley Tax Directors Group, Palo Alto, on permanent establishment profit attribution and the mutual agreement procedure
  • Presenter and panellist, Tax Executives Institute (Asia), The Tax Institute, CTA and client forums
  • Guest lecturer at the University of Melbourne for students studying “Taxation of Intellectual Property” and “Transfer Pricing Practice and Problems”

Prior Experience

  • 2017-2026, Partner and Head of Transfer Pricing Practice at a large Australian law firm. Built the transfer pricing offering from launch; practice recognised as Transfer Pricing Firm of the Year by International Tax Review in 2018, 2019 and 2020
  • Approximately 2004 to 2017, Director, Transfer Pricing, Big Four accounting firm
  • Prior to 2004, Economist at the Australian Taxation Office, focusing on international tax matters and tax data analytics

Memberships and Affiliations

  • Fellow, The Tax Institute; committee member, National Transfer Pricing Conference
  • Consultant to the OECD on Pillar One (Amount A) profit allocation methodology
  • Member, International Fiscal Association
  • Contributor to ATO public consultation on the Australian advance pricing arrangement program, public country-by-country reporting and intangibles guidance

My latest insights

Publication

ATO finalises software royalty ruling and expands practical compliance guidance

16 September 2026 .6 minute read

Connect

Phone

+61 3 9274 5086
(Work, Melbourne)
+61 401 004 635
(Mobile)

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