• Skip to content
  • Skip to navigation

Grant Thornton Australia

Grant Thornton uses cookies to monitor the performance of this website and improve user experience.

If you are happy to accept cookies from this site, please check the box.

To find out more about cookies, what they are and how we use them, please see our privacy notice, which also provides information on how to delete cookies from your hard drive.

How to be COVIDSafe when visiting Grant Thornton offices. Find out how

Global site
  • Global site
  • Algeria
  • Botswana
  • Cameroon
  • Egypt
  • Ethiopia
  • Gabon
  • Guinea
  • Kenya
  • Libya
  • Malawi
  • Mauritius
  • Morocco
  • Nigeria
  • Namibia
  • Senegal
  • South Africa
  • Togo
  • Tunisia
  • Uganda
  • Zambia
  • Zimbabwe
  • Anguilla
  • Antigua
  • Argentina
  • Aruba, Bonaire, Curacao and St. Maarten
  • Bahamas
  • Barbados
  • Bolivia
  • Brazil
  • British Virgin Islands
  • Canada LLP
  • Canada RCGT
  • Cayman Islands
  • Chile
  • Colombia
  • Costa Rica
  • Dominica
  • Ecuador
  • El Salvador
  • Grenada
  • Guatemala
  • Honduras
  • Mexico
  • Montserrat
  • Nicaragua
  • Panama
  • Paraguay
  • Peru
  • Puerto Rico
  • St Kitts
  • St Lucia
  • St Vincent and the Grenadines
  • Trinidad & Tobago
  • United States
  • Uruguay
  • Venezuela
  • Turks & Caicos
  • Afghanistan
  • Australia
  • Bangladesh
  • Cambodia
  • China
  • Hong Kong
  • India
  • Indonesia
  • Japan
  • Korea
  • Malaysia
  • Mongolia
  • Myanmar
  • New Zealand
  • Pakistan
  • Philippines
  • Singapore
  • Taiwan
  • Thailand
  • Vietnam
  • Albania
  • Armenia
  • Austria
  • Azerbaijan
  • Belarus
  • Belgium
  • Bosnia and Herzegovina
  • Bulgaria
  • Channel Islands
  • Croatia
  • Cyprus
  • Czech Republic
  • Denmark
  • Estonia
  • Finland
  • France
  • Georgia
  • Germany
  • Gibraltar
  • Greece
  • Hungary
  • Iceland
  • Ireland
  • Isle of Man
  • Israel
  • Italy - Bernoni
  • Italy - Ria
  • Kazakhstan
  • Kosovo
  • Kyrgyzstan
  • Latvia
  • Liechtenstein
  • Lithuania
  • Luxembourg
  • Macedonia
  • Malta
  • Moldova
  • Monaco
  • Netherlands
  • Northern Ireland
  • Norway
  • Poland
  • Portugal
  • Romania
  • Russia
  • Serbia
  • Slovak Republic
  • Slovenia
  • Spain
  • Sweden
  • Switzerland
  • Tajikistan
  • Turkey
  • Ukraine
  • UK
  • Uzbekistan
  • Bahrain
  • Egypt
  • Jordan
  • Kuwait
  • Oman
  • Qatar
  • Saudi Arabia
  • United Arab Emirates
  • Yemen
  • Lebanon
Grant Thorton Logo

Grant Thornton Logo Grant Thornton Logo

Contact us
  • Insights
  • Services
  • Industries
  • Meet our people
  • Careers
  • News centre
  • Locations
  • About us
  • Audit
  • Tax
  • Private Advisory
  • Financial Advisory
  • Grant Thornton Consulting
  • Asia
Audit Home
  • Audit methodology
  • Audit technology
  • Financial reporting advisory
Tax Home
  • Corporate tax
  • Employee equity reward schemes
  • Fringe benefits tax
  • Global mobility services
  • GST & indirect tax
  • International tax
  • Payroll assurance
  • Research & development
  • Tax compliance
  • Tax governance & risk management
  • Tax in mergers & acquisitions
  • Tax lawyers
  • Transfer pricing
Private Advisory Home
  • Family Business Consulting
  • Family office services
  • Private wealth
  • Superannuation
Financial Advisory Home
  • Corporate finance
  • Debt advisory
  • Forensic consulting
  • Payments advisory
  • Restructuring advisory
Grant Thornton Consulting Home
  • Business risk
  • Human capital
  • Performance improvement
  • Strategy & growth
  • Technology consulting
  • GNC Group Consulting
Asia Home
  • China practice
  • India practice
  • Japan practice
  • Agribusiness, food & beverage
  • Automotive dealers
  • Education
  • Energy & resources
  • Financial services
  • Health & aged care
  • Life sciences
  • Manufacturing
  • Not for Profit
  • Professional services
  • Public sector
  • Real estate & construction
  • Retail & consumer products
  • Technology & media
Agribusiness, food & beverage Home
Bite Size Dealtracker Food, Beverage & Agribusiness industry insights
Key insights for the Australian Food, Beverage & Agribusiness industry.
Financial services Home
  • Banking
  • Fintech
  • Private Health Insurance
  • Superannuation
  • Asset management
  • BEAR FAQs
  • Open banking
Royal Commission wrap up Top 10 things for Financial Services providers
Eleven months on from the first round of hearings for the Royal Commission into Misconduct in the Banking, Superannuation and Financial Services Industry, Commissioner Hayne’s final report has been released.
Health & aged care Home
Aged Care Royal Commission Perspectives on the Future of Ageing
Transitions in ageing are not consistent and systematic as they are described by our ageing systems. Sometimes they are incremental, sometimes accidental, sometimes monumental, and they are always personal. We can create something better.
Life sciences Home
Biotechnology Industry Position survey Australia's biotechnology industry drives economic growth
The 2019 Biotechnology Industry Position survey conducted by Ausbiotech and supported by Grant Thornton has revealed that new technologies across regenerative medicine and medicinal cannabis are disrupting the industry, and Australia's global strength in clinical trials continues to drive contributions to the economic and social fabric of the country.
Manufacturing Home
mid-sized business report Manufacturing is critical to our economy – how can we support the sector?
Although the knock-on effects of the Australian automotive industry exiting our country are yet to be fully understood, the industry is evolving, and manufacturing continues to be a major employer and critical to our overall economy.
Not for Profit Home
NATIONAL OUTCOMES MEASUREMENT PROGRAM A practical framework
Royal Commissions and federal budgets are critical things for Nonprofit human service providers to be thinking about at this point in time.
Real estate & construction Home
mid-sized business report Supporting affordable housing requires planning, certainty – and tax reform
There is a lot of noise around the property sector at the moment – and it’s not all positive. Prices are down – but this shouldn’t be a surprise when some markets (namely Sydney & Melbourne) saw unprecedented hikes in recent years.
Retail & consumer products Home
GNC Group Consulting The Technology Trap: Online innovation in retail
I recently attended the NRF Retail Big Show in New York, an overwhelming smorgasbord of retail technology and new store concepts.
Technology & media Home
  • Telecommunications
Scaling-up for Growth From start-up to scale-up
Navigating the complexities of growth and maintaining previous success is a challenge for all mid-size businesses.
  • Working at Grant Thornton
  • Student opportunities
  • Experienced careers
  • Contact us
Working at Grant Thornton Home
  • Flexibility
  • Your career and development
  • Diversity and inclusion
  • In the community
  • What we offer you
Student opportunities Home
  • Graduates
  • Vacationer Program
  • The application process
  • FAQs
  • Student application tips and tricks
Experienced careers Home
  • Client spotlight
  • Grant Thornton Australia | Audit, Tax and Advisory
  • Client alerts
  • 2018
  • The ATO continues to focus on their use of data to risk profile multinational taxpayers

The ATO continues to focus on their use of data

18 Dec 2018
  • The ATO continues to focus on their use of data to risk profile multinational taxpayers

With the ATO continuing to focus on their use of data to risk profile multinational taxpayers, changes will impact lodgements before the 15th of January. What should you do?

Taxpayers should:

  • ensure that they are able to source the additional information required; and
  • review their tax positions and ensure that appropriate documentation is prepared, as the new disclosures may likely be part of the ATO’s new audit activities.

Data collection is the basis for profiling high-risk multinational taxpayers

The ATO is stepping up its game when it comes to identifying and targeting taxpayers under the new Base Erosion and Profit Shifting ("BEPS") activities.

Additional information will be required by the ATO for the 2018 and 2019 International Dealings Schedules ("IDS").  This data will be used to identify high risk transactions or structures which will likely be the focus of review in the upcoming years.

What additional information is the ATO looking at in 2018?

The ATO is focusing on the areas they consider are causing the greatest erosion to the Australian tax base. As a result, the following disclosures have been added into the 2018 IDS:

  • Question 13f –disclosures on the cost base and margin earned by Australian companies performing intercompany Research & Development activities ("R&D"). These disclosures may result in queries from the ATO regarding the levels of profits made by Australian taxpayers performing these activities and the economic ownership of the intellectual property developed in Australia.
  • Questions 19a and 29b –disclosures on hybrid income and expenses including:
    • hybrid instruments which are considered debt for tax purposes in one country and are treated as equity for tax in another; and
    • cross-border hybrid entities (e.g. hybrid limited partnerships or hybrid companies).
  • These new disclosures will help identify any potential tax savings obtained by taxpayers, which result from the mismatch of giving a different treatment to the same transaction or entity in two jurisdictions. 
  • Question 28b –operating models involving cross-border activities related to procurement, marketing, sales and distribution functions. These disclosures will highlight any large transactions involving related party intermediaries, which could be considered as high-risk transactions by the ATO.
  • Questions 30b, 37a, 37b and 37c – As a result of the ATO's concerns on higher levels of debt deductions, taxpayers are now required to disclose:
    • whether other tests besides the Thin Capitalisation test have been used to support debt deductions (i.e. the Arm’s Length Debt Test or the Worldwide Gearing Debt Amount); and
    • whether any assets have been revalued under the Thin Capitalisation rules.

Proposed changes to the 2019 IDS

  • For the 2019 IDS,  the ATO will continue to primarily focus on high risk multinationals. Therefore, small businesses will not need to complete an IDS unless:
    • their international related party dealings are greater than 50% of their total aggregated turnover (up to a limit of $5m); or
    • are Significant Global Entities (i.e. entities which are the head of, or part of, a multinational group with accounting consolidated revenue greater than $1 billion).
  • Questions 19a and 29b– A complete a new section will be created for these questions, including information on:
    • deductions denied or income assessed directly under the hybrid mismatch legislation; and
    • a description of any restructures or replacement arrangements, where the arrangement that has been replaced would have been subject to the hybrid mismatch legislation.
  • New CFC questions will be introduced to disclose the gross revenue figures for CFCs, regardless of whether they satisfy the active income test or not.
  • New Taxation Of Financial Arrangement ("TOFA") disclosures will be implemented to help identify and manage profit shifting risks associated with TOFA deductions taken for related party financial arrangements which are not treated as debt interests.
  • Australian Financial Institution subsidiary CFCs, which do not have a local financial license will be required to disclose:
    • tainted interest income excluded from passive income; and
    • the number of such CFCs in specified, listed and other countries

For more information, please contact:

Jason Casas

Partner & National Head of Transfer Pricing
+61 3 8663 6433
jason.casas@au.gt.com

Lorena Sosa

Partner - Transfer Pricing
+61 2 8297 2548
lorena.sosa@au.gt.com

Share this page
  • Share this page on Facebook LinkedIn
  • Share this page on Twitter Twitter
  • Share this page on LinkedIn LinkedIn
  • Share this page on Wechat WeChat
  • Share this page via email Email
  • Follow us on youtube
  • Follow us on linkedin
  • Follow us on twitter
  • Follow us on facebook
Connectclose
  • Contact us
  • Locations
  • Meet our people
  • Subscribe
  • Staff portal
Aboutclose
  • About us
  • Careers
  • News centre
  • Client alerts
  • Grant Thornton Foundation
  • Grant Thornton Affinity
Legalclose
  • Privacy
  • Compliance and ethics
  • Disclaimer
  • Site map

© 2021 Grant Thornton Australia Limited – All rights reserved

    • EN
    • Contact us