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On 18 December 2017, the Australian Taxation Office (ATO) published documents providing guidance on the application of Diverted Profits Tax (DPT).
The Diverted Profits Tax (DPT) legislation received Royal Assent on 4 April 2017, with Schedule 1 to the Treasury Laws Amendment (Combating Multinational Tax Avoidance) Act 2017 implementing the DPT and Diverted Profits Tax Act 2017.
On 23 November 2017 the ATO released a communication in relation to December balancers and the lodgement of Country-by-Country (“CbC”) reporting statements.
In October 2017, the Australian Taxation Office (“ATO”) published a document called “Tax and Corporate Australia” where it estimates a $2.5 billion tax gap amongst the top 1,400 large corporate groups in Australia in 2015.
Significant global entities are now required to lodge general purpose financial statements (GPFS) to the Australian Taxation Office (ATO) with their tax return.
The ATO is set to increase compliance activity on the pricing of cross border intragroup funding.
In April 2017, the Full Federal Court ruled against Chevron Australia Holdings Pty Ltd (Chevron Australia) in favour of the Australian Taxation Office (ATO) on appeal in relation to the transfer prices on intragroup funding between the overseas related party (the lender) and the recipient of...
Possibly encouraged by the Chevron Australia decision, on 16 May 2017 the ATO issued a draft Practical Compliance Guidance PCG 2017/D4 (PCG) outlining the risk assessment framework for cross border related party financing arrangements.
The Federal Parliament has passed legislation to implement the Diverted Profits Tax and to introduce a new penalty regime for Significant Global Entities (SGEs). These measures increase the tax and transfer pricing compliance risk for multinational companies (MNEs) in Australia who are SGEs and...