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DPT Submission to Treasury
Deloitte recently lodged its submission in respect of the proposed Diverted Profits Tax (DPT) with Treasury.
Our key submissions were:
If the objective is to improve the way in which the process of dispute management and resolution is undertaken in the case of un-cooperative taxpayers, this objective could be achieved without the complexity of the DPT. In particular, targeted amendments could be made to the existing assessment, enforcement and collection mechanisms.
If the DPT is targeted at un-cooperative taxpayers, this group of taxpayers should be legislatively defined, and can be done by reference to existing concepts in the penalty provisions that apply to taxpayers that take “steps to prevent or obstruct the Commissioner”.
It should be made clear that the DPT is not intended to expand Australia’s tax base. Some of the examples indicate that the DPT is expanding the scope of Australian tax beyond the existing law such as transfer pricing and Part IVA.