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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

ATO perspective on international tax administration issues

Jim Killaly

Deputy Commissioner of Taxation

Large Business and International

administration issues design issues
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
administration issues
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
administration issues difficulties for taxpayer and ato

Administration issues - difficulties for taxpayer and ATO

Definitional issues

Tainted sales

Tainted services

Residency issues for companies and expats

administration issues difficulties for taxpayer and ato1

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

administration issues difficulties for taxpayer and ato2

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

administration difficulties integrity issues
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
administration difficulties integrity issues1
Administration difficulties - Integrity issues
  • Criteria to quarantine measures to their intended scope
  • Capital adequacy and appropriate accounting for branch structures
administration issues1
Administration issues
  • Integrity issues
  • Other administration issues
    • Skilling -
      • both within and outside the ATO
    • Systems
      • IT
      • Returns