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ATO perspective on international tax administration issues

ATO perspective on international tax administration issues. Jim Killaly Deputy Commissioner of Taxation Large Business and International. Administration issues - design issues. Design principles to help administrability Alignment with underlying business, market and economic realities

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ATO perspective on international tax administration issues

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  1. ATO perspective on international tax administration issues Jim Killaly Deputy Commissioner of Taxation Large Business and International

  2. Administration issues- design issues • Design principles to help administrability • Alignment with underlying business, market and economic realities • Rules do not get in the way of the market • Ensuring integrity of the policy - delivery of benefits and guarding against unintended advantages • Facilitating streamlining and efficiency for all parties

  3. Administration issues • Design principles • Ability of the system to operate in real time for taxpayers and the ATO, especially in the context of self assessment

  4. Administration issues - difficulties for taxpayer and ATO Definitional issues Tainted sales Tainted services Residency issues for companies and expats

  5. Administration issues - difficulties for taxpayer and ATO Record keeping concern Substantiation in relation to active income test Investments realised to avoid complexities of FIF attribution accounting

  6. Administration issues - difficulties for taxpayer and ATO Design issues driving compliance costs Interface between CFT and FIF measures Interface between the CFC and FIF measures

  7. Administration difficulties - Integrity issues • Preserving the integrity of the listed/unlisted country distinction and listing approach • Section 47A • Criteria for listing jurisdictions as comparably taxing

  8. Administration difficulties - Integrity issues • Criteria to quarantine measures to their intended scope • Capital adequacy and appropriate accounting for branch structures

  9. Administration issues • Integrity issues • Other administration issues • Skilling - • both within and outside the ATO • Systems • IT • Returns

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