Competent Authority services
Tax administrations around the world are becoming increasingly aggressive and sophisticated at enforcing their transfer pricing regimes, which means multinational groups are facing an increasing risk of transfer pricing adjustments. However, the worst case scenario is not a transfer pricing adjustment - painful as this may seem - but paying tax on the same income twice because Competent Authorities will not provide relief from double taxation.
A multinational group facing double taxation can generally seek relief under a double tax treaty via the Competent Authority in their tax jurisdiction. Under this procedure, the tax administrations involved attempt to resolve the double taxation by mutual agreement. If the Competent Authorities fail to agree, income may be subject to double taxation.
Companies that actively manage the Competent Authority process achieve better results. The Australian Competent Authority is allowing an increasing role for companies in the process, and Deloitte can assist by using the resources of our pre-eminent International Competent Authority team (ICAT) all around the world.
Our Australian team is the market-leader, comprising Australia’s most experienced and respected competent authority negotiators:
- David Grecian – former Australian Competent Authority
- David Lewis – former Australian Competent Authority.
The same high level of service is available in foreign tax jurisdictions as many of Deloitte’s ICAT members were also with their country’s Competent Authorities. Some of these experts include Gary Zed in Canada (ex-Canada Customs and Revenue Agency Competent Authority) and Ron Haigh (ex-Inland Revenue Competent Authority).