In a speech in NZ on 30 October, 2010, Tax Commissioner Michael D'Ascenzo said the key message from a recent OECD report to the G20 is that abusive tax arrangements are under the microscope and that global cooperation combined with the best technological applications "is gathering a head of steam".

Mr D'Ascenzo also made the following points.

Joint audits
The ATO is involved in a pilot project involving joint audits with other revenue/other jurisdictions to develop "joint audit examination products" on issues of common interest. He said the purpose of these "products" would be to minimise or eliminate double tax issues and reduce the need for Mutual Agreement Procedure cases.

High net-worth individuals
The Tax Office is currently trialling a system of Advance Compliance Agreements with a small number of high-wealth individuals, where there is a sharing of tax risks. The Commissioner said the aim is to facilitate the sharing of experiences and approaches in dealing with the high net-worth population. The Commissioner said 14 countries are currently participating in this new network.

Bank losses
The Commissioner said this project will deal with risks involving large business losses, particularly from the banking sector, and explore the different approaches for giving tax relief to loss-making taxpayers. The ATO has a current focus on role structured finance arrangements and transfer pricing.

Other points highlighted by the Commissioner:

• Concerning Australia and NZ, the ATO keeps a close eye on cross-border tax arbitrage.
• NZ IRD recently assisted the ATO in recovering a large tax debt against various entities, some of whom were known to have funds in New Zealand bank accounts.