Media Release: Clayton Utz to co-host Australian and US tax regulators in conversation, with dispute management on the agenda

01 Mar 2023
Time to read: 1 minutes

Clayton Utz has teamed up with US firm Greenberg Traurig LLP to bring together our respective countries' tax regulators — the Australian Taxation Office (ATO) and Internal Revenue Service (IRS) — to share their insights into their current priorities, and approach to cross-border tax disputes.

Rebecca Saint (ATO Deputy Commissioner, Public Groups & International) and Jennifer Best (IRS Deputy Commissioner, Large Business & International) will take part in a live-streamed conversation on Wednesday 8 March (Australian time), moderated by Clayton Utz Tax partner Angela Wood and Greenberg Traurig's Sharon Katz-Pearlman.

One of the key discussion topics will be dispute management and resolution, with an increasing number of multinationals involved in tax disputes in the US and Australia particularly for transfer pricing issues.

Angela said the discussion was timely against the backdrop of the continued upward trend in cross-border tax disputes, coupled with the OECD's efforts to reduce the number of disputes through greater harmonisation of tax rules globally:

"We're arguably at an inflection point in terms of greater co-operation and consistency between tax regulators globally, the aspiration of which is to give greater certainty to taxpayers as to how to manage their operations globally and mitigate the risk of being drawn into lengthy tax disputes.  It is as yet unclear how the intended high level of co-operation between governments on tax issues will play out.

From my many years' experience in advising clients on dispute management, it's critical to have an open line of communication with the key regulators and a proper understanding of the regulatory environment, current thinking and approaches. We're really pleased that Rebecca and Jennifer have agreed to participate in what we anticipate will be a very frank and open discussion".

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Clayton Utz communications are intended to provide commentary and general information. They should not be relied upon as legal advice. Formal legal advice should be sought in particular transactions or on matters of interest arising from this communication. Persons listed may not be admitted in all States and Territories.