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Reportable tax positions and the ATO’s great expectations paper

Published on 14 Mar 12 by NATIONAL DIVISION, THE TAX INSTITUTE

This paper covers:

  • what is a reportable tax position?
  • the ‘grey areas’ - Commissioner’s discretions (including Part IVA), transfer pricing and market valuations
  • what should taxpayers consider in relation to RTP disclosures?
  • uncertain tax positions - The US experience.

Author profiles

Paul McCartin CTA
Photo of author, Paul McCartin Paul McCartin is a Partner in PwC Australia's tax controversy and dispute resolution team. Paul has over 18 years of tax experience and joined PwC after 12 years working at senior levels of the Australian Taxation Office (ATO) in tax policy, audit, OECD projects and technical interpretation areas. He is a former ATO Competent Authority and from 2009 - 2010 was the ATO's delegate on the Joint International Tax Shelter Information Centre (JITSIC) where he was based in Washington DC. In this role Paul focused on coordinated revenue authority tax audits of multinational companies. Paul uses his ATO technical and compliance experience, coupled with his understanding of the ATO and international tax administration 'mindset', to specialise in assisting clients to strategically and effectively manage risk reviews, audits and objections. Paul has particular expertise in managing disputes with the ATO having resolved a number of significant and complex tax disputes for listed public companies, private groups and high net wealth individuals. Paul was recognised in the International Tax Review Tax Controversy Leaders Guide for 2014 and 2015 and is a current member of the ATO's Large Business Stewardship Group. - Current at 12 September 2016
Ronen Vexler
Photo of author, Ronen VEXLER Ronen is a Partner in PwC’s Tax Reporting & Strategy practice. He has significant experience advising clients on all aspects of tax management, from developing and embedding Tax Strategies, Policies and Technology through to reviews of specific tax processes and controls. He has a deep knowledge of the Australian Taxation Office’s (ATO’s) compliance strategies, and in particular, the ATO’s expectations for tax risk management and governance. He has worked extensively with a broad range of clients to develop and document the systems and processes necessary to meet these expectations. - Current at 04 March 2021
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This was presented at 27th National Convention .

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Individual sessions















ATO approach to dispute resolution

Author(s):  Deborah HASTINGS

Materials from this session:






Commissioner's address

Author(s):  Michael D'ASCENZO

Materials from this session:

Board of Taxation update

Author(s):  Chris JORDAN

Materials from this session:

Tax and the Constitution

Author(s):  The Hon Robert French, AC

Materials from this session:

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