On 2 June 2014 the Federal Government published a report by the
Inspector General of Taxation ("IGT") on the Australian
Taxation Office's ("ATO's") management of
transfer pricing matters.
The IGT found the ATO's capability to manage transfer
pricing matters 'wanting' in a number of important areas.
Whilst the 'headline' numbers look excellent (18
recommendations of which the ATO "agreed" with 17 [in
whole or in part or in principle]) important considerations remain.
This is so as 6 of the IGT recommendations have only been agreed to
in part and the absence of agreed timelines to address some of the
recommendations, to which the ATO did agree, is unfortunate.
Perhaps most notably, the ATO has refused to agree that transfer
pricing decision-making authority should fall to officers that have
a "...solid grounding in transfer pricing..." This
coupled with the fact the ATO has not agreed to another IGT
recommendation, that the ATO establish an "overseeing
body" to
