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What attracts our attention

To help you get things right, consider the behaviours, characteristics and tax issues that attract our attention.

Last updated 15 December 2015

We focus on six key industries: superannuation, insurance, energy and resources, banking and finance, manufacturing, and sales and services. Across all industries we look at particular tax risks, such as losses and international profit shifting, and particular events in the business lifecycle, such as private equity investments.

Increasingly we seek to understand taxpayers' business models, tax performance and changes/variations over time or relative to peers. We want to identify compliance risks and opportunities for enhanced taxpayer service. By clustering common issues across taxpayers we can treat them in a more timely, consistent and effective manner – for example, we are reviewing the offshore service hubs used by several mining companies to address profit shifting risk through transfer pricing.

The following issues will attract our attention:

  • capital gains tax
  • losses – capital and revenue
  • profit shifting
  • concessions
  • offshore evasion
  • trusts
  • consolidation
  • financial arrangements
  • integrity of business systems for GST and excise obligations
  • GST and property transactions
  • GST international and cross border issues
  • GST financial supply transactions and the application of apportionment

The following structuring and business events will also attract our attention:

  • mergers and acquisitions
  • divestment of major assets and demergers  
  • share buy backs
  • capital raisings and returns of capital
  • private equity entries and exits
  • initial public offerings
  • infrastructure investments
  • cessation of business operations in Australia.


Corporate restructures involving acquisitions and disposals are a priority focus for the ATO.