Expert Analysis

Maslak Mahallesi Bilim Sk No: 5

Michael Bersten, Paul McCartin and Caleb Khoo PwC The tax audit and controversy landscape in Australia continues to shift and evolve against a backdrop of the federal government's commitment to addressing base erosion and profit shifting (BEPS) and to increase revenue collections. The focus on the Australian budgetary position has contributed to the Australian government introducing a number of legislative changes with the stated purpose of limiting perceived areas of potential revenue leakage. Recent changes include clarifications to Australia's general anti-avoidance and transfer pricing rules. In addition to legislative responses, the Australian government has provided additional budgetary funding to the Australian Taxation Office (ATO) to enable it to focus on areas considered to be high risk, such as cross-border financing or business restructures. In this environment, the ATO is adopting a far more evidentiary based, or litigation-ready approach to information gathering. This approach has been in response to a number of factors such as court losses which may, at least in part, be attributed to insufficient evidence collection and the recent limitations on the Commissioner's powers of discovery. This has meant that the ATO will increasingly seek to collect its evidence during the audit and objection stage rather than before litigation.

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