It has been a big 12 months in international tax and transfer pricing. At a global level, we have seen ongoing pressure on governments to raise revenue, trade tensions between major political powers and rapidly evolving business models. Against this backdrop, multinational taxpayers, their advisers and tax administrations are being required to navigate an environment that is more complex, more uncertain and more public than ever before. Familiar themes like related party financial dealings, intangible assets and the taxation of real property remain as complex and contested today as they have ever been. Less familiar themes, like tax transparency, the exchange of information and mandatory binding arbitration, are emerging as major challenges for taxpayers and the ATO. Understanding the forces behind global trends and keeping abreast of domestic developments is essential to remaining at the forefront of international tax today.
This year’s Masterclass was carefully curated to reflect these challenges. Across the one-day event, some of Australia’s leading tax professionals explored what is most relevant in tax policy and practice. The event covered recent developments in cross-border tax disputes and administration, the proliferation of M&A tax issues and the emergence of tax transparency and governance as a core component of modern tax functions. The event also considered major legislative, case law and practical developments, including in the context of intragroup finance, the general anti-avoidance rule in Part IVA and the rollout of Pillar Two.