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Increased ATO activity in a post-BEPS environment – paving the way for more Mutual Agreement Procedure cases

Tax insights

As cross-border business and multinational enterprises play such a key role in the global economy, bilateral disputes relating to which jurisdictions can tax certain types of income inevitably arise. Following the Organisation for Economic Co-operation and Development Base Erosion and Profit Shifting reforms, the Australian Taxation Office has ramped up its Streamlined Assurance Review and audit activity, in parallel with increased tax audit activity in foreign jurisdictions. The COVID-19 economic downturn has also complicated taxpayer positions, due to its impact on profitability in many sectors. Mutual Agreement Procedure will be used more frequently to resolve bilateral disputes in the coming months and years.

Increased Mutual Agreement Procedure cases
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