21 Oct 11 International Dealings Schedule – update on consultation
Tax Counsel Tamera Lang ATIA joined a teleconference hosted by the ATO about the new International Dealings Schedule (IDS) on 18 October 2011. As reported in last week’s TaxVine, the IDS will replace the current Schedule 25A and thin capitalisation schedule, and follows the development of an IDS for the financial services industry.
Prior to the teleconference, the ATO provided an updated draft of the IDS which incorporated feedback from the professional bodies’ representatives. Some other feedback which has been provided is still under consideration. Draft instructions which will accompany the IDS were provided.
Some of the issues discussed by the working group to date include:
- the treatment of branch/permanent establishment “dealings”;
- the appropriate definition of an “international related party”;
- whether responses to certain questions should be reported as accounting or tax values, and whether derivative transactions should be reported at gross or net value;
- how levels of documentation should be disclosed;
- how acquisitions/dealings with shares, debts and swaps should be reported; and
- how restructures should be reported (and whether thresholds are desirable).
The consultation on the IDS will continue next week. If you are interested in viewing a copy of the draft IDS and accompanying instructions, please contact us at Tax Policy. We would be grateful for your feedback on this important new schedule, and we will ensure that your views are communicated to the ATO.