Daily Archives: September 7, 2019

Productivity Commission recommends – abolish ‘Zone Tax Offset’; Refresh Remote Area Allowance; Keep FBT Remote Area Concessions

On 4.9.19, the Productivity Commission today released a draft report on Remote Area Tax Concessions and Payments. The Government tasked the Commission to assess the zone tax offset (ZTO), the remote area allowance (RAA) and the FBT remote area concessions. See below for further detail. FJM 7.9.19 [Tax Month – September 2019]     ‘Tax…

IGTO issues its ‘operational guidelines’ for both ‘complaints’ about ATO decisions and also reviews and investigations into ‘systemic’ ATO issues

In early September the Inspector-General of Taxation and Taxation Ombudsman (IGTO) has published its operational guidelines for both complaints handling and its reviews of ‘system’ problems within the ATO. See below for links to these operational guidelines and a short summary of them. FJM 7.9.19 [Tax Month – September 2019]              

ATO’s ‘take’ on their Glencore transfer pricing loss – they’re considering an appeal – but otherwise extol the virtues of ‘arms -length’ pricing

The ATO is considering whether to appeal the Federal Court decision in Glencore Investment Pty Ltd v FCT [2019] FCA 1432. The case considered whether dealings between Swiss-based Glencore International AG and an Australian subsidiary breached the transfer pricing rules in relation to the sale and purchase of copper concentrate (see related Tax Technical article).…

Glencore Investment Pty Ltd v CofT – ‘Swiss Head Co – Aus Sub’ Pricing Agreement did not offend either Div 13A or Subdiv 815-A Transfer Pricing Provisions (within arm’s length and restructuring agreement not permitted)

On 3.9.19, the Federal Court has held that the price paid by the a different Glencore company (to the one involved in the recent High Court ‘legal professional privilege’ case) to its Australian subsidiary, for copper concentrate, was within an arm’s length range for transfer pricing purposes. See related Tax Technical article for the ATO’s…

Taxation of the Digitalised Economy – An Informal Update by Tony Stolarek given to the Melbourne Taxation Discussion Group

Tony Stolarek of Consulting Firm: E&Y, presented an Informal Update on the ‘Taxation of the Digitalised Economy’ to the July 2019 meeting of the Melbourne Tax Discussion Group. In aid of this he circulated the Power Point presentation, which appears below. See below for the Presentation and a summary of it. FJM 7.9.19 [Tax Month…