The Australian Taxation Office (ATO) in accordance with current base erosion and profit shifting (BEPS) activities dispatched an “international structuring and profit shifting” (ISAPS) field review program.
This is a decentralized national program involving over 100 ATO officers and will follow a “client risk review’ and rating methodology approach. A key, controversial issue associated with these reviews is the ATO’s desire to review information associated with the overseas aspects of taxpayers’ global structures so that the tax authorities can understand the broader context of transactions and operations.
