About the program
The Private Wealth (PW) International Program supports the Tax Avoidance Taskforce through engaging with privately owned and wealthy groups that have international operations and dealings. The Program seeks to give the community confidence that privately owned groups are paying the right amount of tax.
Our program delivers 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.
As part of the program, we're also providing input to relevant new international tax measures affecting private groups.
For information about other PW programs, see:
- Tax performance programs for privately owned and wealthy groups
- Commercial deals program
- Tax Avoidance Taskforce – Trusts
- Promoters and Tax Exploitation Program
Our population
Our population includes all privately owned and wealthy groups that engage in international dealings including those that are covered by the Top 500, Next 5,000, and Medium and Emerging tax performance programs.
We provide dedicated support to the tax performance programs to identify and address international risks. We also collaborate with stakeholders across the ATO to ensure international risks are treated consistently.
International risks that we're focused on
Our program focuses 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.
There are other international issues that 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.
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). See who must complete an IDS for circumstances that an IDS must be lodged. Refer to Forms and instructions for the relevant income year to help you complete the IDS.