Part 6: Private Groups – ATO ramps up review activity
In November 2019, the ATO announced an expansion to its ‘Tax Avoidance Taskforce’, increasing its focus on “supporting and ensuring private groups and high wealth individuals pay the right amount of tax”. This followed the Commonwealth Government's 2019/20 Budget announcement to provide additional funding of $1 billion over four years to extend the Taskforce’s operation until the 2022/23 income year.
International tax risks including transfer pricing will be a key focus of the taskforce with the ATO engaging with private groups across their programs of work with the aim of helping groups meet their tax compliance obligations in respect of their international dealings.
This session is designed as a Q&A session and will begin with the ATO providing an overview of the programs of work focused on private groups followed by a Q&A session exploring the following key transfer pricing areas likely to be focused on during the reviews and engagements undertaken:
– The transfer pricing questions contained in the Next 5000 program’s ‘Request for Information’ template;
– Details of the ATO Private Wealth team’s transfer pricing focussed risk clusters on related party financing; intangible migration and other relevant risk clusters;
– Expectations regarding transfer pricing documentation for private groups including the use of Simplified Transfer Pricing Record Keeping Options;
– Understanding changes to the definition of SGE’s and its impact on private groups;
– The ATO’s focus on Private Groups failing to or incorrectly lodging International Dealing Schedules; and
– Expectations regarding transfer pricing disclosures on the Reportable Tax Position schedule currently being rolled out to private groups.