• Service: Tax, Corporate Tax, Global Transfer Pricing Services, Dispute Resolution
  • Type: Business and industry issue
  • Date: 30/04/2013

Tax Insights

KPMG's analysis of tax issues and developments.

Jeremy Geale

Jeremy Geale
Partner, Tax

+61 2 9335 8422

Guarding against tax disputes in a time of global uncertainty 

by Jeremy Geale, Tax Law Specialist

At the recent KPMG Asia Pacific Tax Summit, Pascal Saint-Amans, Director of the Centre for Tax Policy & Administration, delivered an overview of the current and emerging developments in global tax policy. The focus of that tax policy is addressing base erosion and profit shifting and specifically double non-taxation. 

Whilst Mr Saint-Amans was optimistic that global consensus could be achieved on the measures needed to address these issues, it was acknowledged that such consensus would be difficult. As he pointed out, unless global consensus can be reached countries will act unilaterally, the consequences of which are uncertainty, greater use of general anti-avoidance provisions and regrettably, more tax disputes.


So in an environment of global uncertainty, what can clients do to guard against disputes, or at least ensure they are best placed to resolve disputes when they arise? In answer to that, traditional advice still holds — clients need to be prepared, organised and in complete control of the facts and issues. The most common mistake clients can make is to neglect the facts or fail to collate evidence to support assertions about those facts.


These days, best practice for taxpayers is to collate documents and statements in real time, as transactions progress. This not only ensures taxpayers are able to defend the positions they have adopted in the future, but it places them in the best position to promptly and effectively respond to ATO enquiries, taking hold of the engagement process and resolving issues before they escalate into disputes.


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