Tax & Accounting Blog

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TAX AND ACCOUNTING PROFESSIONALS

Catch me if you can – Transfer Pricing in the quantum age of speed and transparency

May 4, 2018

Data transfers between tax authorities in the supercomputer age will be made at lightning speed, allowing them to size-up in mere moments the veracity of a company’s declaration of cross-border structures and revenue models. While we might not be in the quantum age just yet, companies have started leveraging technology to produce accurate CbC reports and transfer pricing documentation.

Catch me if you can – Transfer Pricing in the quantum age of speed and transparency

Catch me if you can – Transfer Pricing in the quantum age of speed and transparency

Data transfers between tax authorities in the supercomputer age will be made at lightning speed, allowing them to size-up in mere moments the veracity of a company’s declaration of cross-border structures and revenue models. While we might not be in the quantum age just yet, companies have started leveraging technology to produce accurate CbC reports and transfer pricing documentation. … Read More

International tax complexity for Australian investments: a real-world example

International tax complexity for Australian investments: a real-world example

With a quarter of all foreign investment in Australia coming from the United States, it is important to consider the potential impact of the US tax reforms on inbound Australian investments. A recent court case has provided a real-world example of how US private equity investors can structure certain Australian investments to deliver “look through” treatment for the purposes of US tax law. … Read More

100% Pure BEPs: NZ responds to the OECD’s BEPs Action Plan

100% Pure BEPs: NZ responds to the OECD’s BEPs Action Plan

With the introduction of a new tax bill in New Zealand to counter multinationals’ BEPs activities, it is a good time to revisit Australia’s own BEPs progress. … Read More

Did we learn anything from the Chevron transfer pricing case? Has arm’s length price passed its use-by date?

Did we learn anything from the Chevron transfer pricing case? Has arm’s length price passed its use-by date?

In August 2017, Chevron Australia announced that it would abandon its ongoing transfer pricing dispute with the ATO.  This announcement means that, for the next few years at least, the Full Federal Court’s judgment handed down in April 2017 (Chevron Australia Holdings Pty Ltd v FCT [2017] FCAFC 62, reported at 2017 WTB 16 [486]) represents the leading authority […] … Read More

BEPS: Overcoming the obstacles to country-by-country reporting

BEPS: Overcoming the obstacles to country-by-country reporting

The new BEPS regime is tripping up tax executives globally – which could cost enterprises hundreds of thousands in penalty fees. Country-by-country reporting is a core element of the Base Erosion and Profit Shifting (BEPS) measures now being implemented for Australian multinationals. The first BEPS reports are due on 15 February 2018, and most Australian […] … Read More

Australia: Making BEPS CbC reports public – “a shame to kill the golden goose”

Australia: Making BEPS CbC reports public – “a shame to kill the golden goose”

At an Australian Senate Estimates hearing on October 25, 2017, Australian Tax Commissioner Chris Jordan was asked to respond to calls for making country-by-country (CbC) reports public. He was asked whether releasing those reports to the public would be of help to the Australian Taxation Office (ATO). Mr. Jordan said if the reports were required to be made […] … Read More