In a speech last week ATO’s Mark Konza, Deputy Commissioner – International, gave an insight into the ATO’s activities in responding to a number of the OECD’s post Cairns G20 Minister’s Conference BEPS Action Plan items.

Deputy Commissioner Konza put particular emphasis on the ATO’s strategy in connection with “Action Item 1: address the tax challenges of the digital economy”. Commenting on the ATO’s work on this aspect he said-

“The broader digital economy is also being addressed through our four-year dedicated compliance program to address International Structuring and Profit Shifting (ISAPS). Tax and law professionals from external firms have been recruited into the ATO to help undertake this work. (Emphasis added)

The program is now in its first full year after setup and we continue to focus on companies that have undertaken international restructures or have significant levels of cross-border related party arrangements.

We are currently investigating 86 multinationals over their tax planning arrangements. (Emphasis added) Based on intelligence gathered from risk filters and early profiling work, we have seen trends in key ratios and overall financial outcomes that have raised some concerns for us. This is particularly apparent where those trends are inconsistent with broader industry performance.”

The full text of Deputy Commissioner Konza’s speech can be found on the ATO website at- https://www.ato.gov.au/printfriendly.aspx?url=/Media-centre/Speeches/Other/BEPS—a-progress-report-on-G20/OECD-action/