This KPMG U.S. International Corridors webcast will cover topical tax matters in the Australian tax landscape including developments in the Australian hybrid mismatch rules and the recent guidance released by the Australian Taxation Office (ATO) on its review of the income tax risk management and governance of large taxpayers. Join our webcast to learn more about these topics and gain insights into how to be prepared for ATO review activity.
You'll learn about:
- Hybrid Mismatch (HMM) Rules: The HMM rules remain a key area of focus of the ATO. Our panelists will discuss the recent finalization of new ATO guidance (PCG 2021/5 and TD 2022/9) and the level of compliance required to conform with the ATO’s expectations in a number of contexts:
1. Identifying and evaluating imported hybrid mismatch issues across multinational groups;
2. The review, documentation and disclosure requirements in order to file Australian tax returns and schedules; and
3. The importance of preparing robust documentation during and before the tax return process with an eye to ATO review, potential challenge and tax disputes.
- ATO review activity – Tax Governance and Combined Assurance Reviews (CAR): The ATO has released detailed guidance on what it expects and how it will review income tax risk management and governance for large taxpayers, including tax controls and related testing. This is very relevant for US multinationals investing into Australia who are often unaware of the relatively high degree of scrutiny and depth of questions/information requested by the ATO. Our panelists will discuss the ATO’s expectations as set out in the guidance and through their direct experience assisting clients across different industry sectors, sizes and geographies with preparing for these review.
- Treasury releases consultation paper on multinational tax integrity and tax transparency: The panel will discuss key tax law reform for multinationals under the Australian Government’s ‘Plan to Ensure Multinationals Pay Their Fair Share of Tax’, including the recent consultation released by Treasury covering the proposals relating to the taxation of multinational enterprises (MNEs) and tax transparency more broadly.
This webcast will last approximately 60 minutes. One continuing professional education (CPE) credit is available to U.S. participants who meet the eligibility requirements. After registering, you will receive details on how to log in to the webcast.