How to make that change

In order to get buy-in from senior management it is often about setting the right priorities, understanding the root cause of underperforming and select a method for measurement that best fits. The deck explains what a tax function could do to get indirect tax higher on the priority list of senior management.

Is it all less challenging when change is initiated and sponsored by senior management itself? For example when the overall business framework is changed (e.g. COSO ERM) or non routine transactions are considered.

The video is 2 minutes slides-only and silent – you may want to use the pause button.

More detail: Where you are and where you want to go

Planning of non-routine transactions

From a Tax Control Framework perspective, for setting up risk based controls, the more unusual the transactions, the greater the tax risks. Examples of non-routine significant business transactions:

1. Migration to new jurisdictions
2. Change of business models
3. The Intersection of VAT and shared service centers
4. M&A integration: managing the moving parts before, during, and after a transaction

The Australian Tax Office (ATO) Practice Statement

Tax benefits/avoidance & GAAR

Australia's effort to change the international tax arena. This practice statement is a draft for consultation purposes only.  Interested parties should submit comments by 25 September.

When the final practice statement issues, it will have the following preamble: This practice statement is an internal ATO document, and is an instruction to ATO staff.

Taxpayers can rely on this practice statement to provide them with protection from interest and penalties in the following way.

If a statement turns out to be incorrect and taxpayers underpay their tax as a result, they will not have to pay a penalty. Nor will they have to pay interest on the underpayment provided they reasonably relied on this practice statement in good faith.

However, even if they don't have to pay a penalty or interest, taxpayers will have to pay the correct amount of tax provided the time limits under the law allow it.

This practice statement is designed to assist Tax officers who are contemplating the application of Part IVA or other GAARs to an arrangement, including in a private ruling, Public Ruling (including a Product Ruling or a Class Ruling) or other document setting out the ATO view.

• Trends
• Audit Defense