House of Representatives Committees

| House of Representatives Standing Committee on Economics

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Advisory Report on the Tax Laws Amendment (Countering Tax Avoidance and Multinational Profit Shifting) Bill 2013

21 March 2013

View the report as a single document - (PDF 651KB)

View the report as separate downloadable parts:


Preliminary pages	(PDF 260KB)

Chapter 1 Introduction	(PDF 198KB)
Referral of the Bill Origins and purpose of the Bill Overview Context of amendments Prior consultation by Government The current anti-avoidance regime The new law Schedule 2 – Modernisation of the transfer pricing rules OECD Guidelines Context of amendments Prior consultation by Government Current transfer pricing rules The new law Date of Effect Objectives and scope of the inquiry Conduct of the inquiry

Chapter 2 Issues in the Bill	(PDF 240KB)
Schedule 1 – General anti-avoidance rules Response to court decisions Analysis Conclusion Operation of alternative postulates Analysis Conclusion Alternative postulates and commercial decision making Analysis Conclusion Technical issues Analysis Conclusion Schedule 2 – Modernisation of the transfer pricing rules Consistency with OECD Guidelines and reconstruction of transactions Analysis Conclusion Time limits to amend assessments Analysis Conclusion Record keeping to support a ‘reasonably arguable’ position Analysis Conclusion Overall conclusion

Coalition Members’ Dissenting Report	(PDF 83KB)

Appendix A – List of Submissions	(PDF 32KB)

Appendix B – List of reports	(PDF 37KB)