Strategizing Multinational Tax Risks

The referenced PwC Alert highlights the proactive efforts by the Australian Tax Office (ATO) to initiate dispute resolution mechanisms in the audit process, as well as focus on relevant internal training to successfully accomplish these objectives.

Click to access TaxTalk-Alert-Tax-Controversy-01Feb14.pdf

The ATO is committed to the following objectives:

• Early engagement and direct negotiation with taxpayers
• Improving all dispute resolution processes starting with the assessment
• ADR utilization at every stage of the dispute resolution process
• Independent review of the audit position prior to conclusion of the audit aimed to narrow / reconsider the issues
• Internal ADR training
• Focused “risk-focused” approach to managing disputes

The ATO’s initiatives are timely, relevant and a welcome effort to adopt Best Practices to resolve disputes prior to costly and time-consuming formal unilateral, bilateral or multilateral appeal avenues via domestic legislation and/or double tax treaty relief.