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Reportable tax positions and the ATO’s great expectations paper


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 Sydney corporate tax practice, with experience across a broad range of taxation issues including compliance, due diligence and structuring. He has assisted on a broad range of clients, both inbound and outbound and of various sizes. Ronen leads PwC Australia's Tax Accounting Services practice. He has been a Tax Accounting specialist for over 15 years and has been the lead tax partner of many statutory audits. Ronen has extensive expertise assisting large companies understand day to day tax accounting issues, as well as the tax accounting consequences of changing tax law, changing accounting standards, and merger and acquisition activity. He is a frequent presenter on tax accounting issues. - Current at 25 February 2015
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This was presented at 27th National Convention .

Get a 20% discount when you buy all the items from this event.

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:

Further details about this event:


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