Australian Government - Australian Taxation Office crest


Mr Ali Noroozi
Inspector-General of Taxation
GPO Box 551

Dear Ali,

Review into the ATO's management of transfer pricing matters.

Thank you for the opportunity to comment on the final draft of your report on the review into the ATO's management of transfer pricing. I would like to acknowledge (fie efforts of all involved in undertaking this review.

I welcome your draft report's constructive feedback and specific recommendations which will assist us to continue improving our management of transfer pricing matters.

We agree either fully, in principle or in part with 17 of the 13 recommendations.

We disagree with your recommendation 2.6, which is about maintaining an overseeing body of specialists with review functions. It is essential that compliance officers are directly accountable for the decisions they make and are supported by specialist advice, as required. Interposing an 'overseeing body' is contrary to that fundamental principle.

The Large business and tax compliance booklet outlines processes for taxpayers to present their position where they disagree with the case team. There are also internal escalation processes where the case team disagrees with the specialist advice provided.

Our detailed response to your recommendations is attached at Annexure 1.

If you require further information on our response, please contact David Allen, Assistant Commissioner.

Yours sincerely


Bruce Quigley
Second Commissioner of Taxation

4 December 2013

[To minimise space, the appendix to the ATO's response has not been reproduced here, but has been inserted into the text of this report underneath each of the recommendations to which that text relates.]