Our population
Our population includes all privately owned and wealthy groups that engage in international dealings. This includes groups that are covered by our Top 500 and Private groups tax performance programs.
We provide dedicated support through our tax performance programs to identify and address international risks. We also collaborate with stakeholders across the ATO to ensure international risks are treated consistently.
We deliver a combination of approaches to help you understand and comply with your tax obligations, including:
- education campaigns to raise awareness about new measures or guidance
- developing public advice and guidance on international tax
- partnering with you through early engagement activities to provide certainty on significant transactions and events
- targeted risk campaigns, risk-based reviews, and audits where appropriate, based on risk assessments from a wide range of internal and external data sources.
We also provide input to relevant new international tax measures affecting private groups.
International risks we're focused on
We focus on treating the following key international tax risks:
- Related party financing risk
- Intangibles migration
- Controlled foreign companies (CFC)
- Non-resident withholding tax
- Tax residency (both individual and corporate)
- Related party service arrangements.
Other international issues also attract our attention. For more information, see International transactions.
In some cases, we have also observed poor record-keeping, reporting and lodgment practices. To learn about your record-keeping requirements, see Overview of record-keeping rules for business.
International related party dealings
If you have international operations and transactions, you should consider if these dealings satisfy the definition of international related party dealings. If so, you must consider if you're required to lodge the international dealings schedule (IDS).
For assistance, see:
- Who must complete an IDS for circumstances when you must lodge an IDS.
- Forms and instructions for the relevant income year to help you complete the IDS.