Managing cross-border tax investigations: a UK and Australian perspective

In our latest Horizon Scanning podcast, Zoe Andrews is joined by Jamshed Bilimoria and Louise Giorgini, Senior Associate at Corrs Chambers Westgarth, to discuss the growing risks posed by cross-border tax investigations and how multinational groups can manage them effectively.

Tax authorities worldwide have stepped up compliance and enforcement activities, and taxpayers increasingly face complex, multi-jurisdictional enquiries, including joint audits where several authorities coordinate their examinations simultaneously.

This episode explores:

• The increasing powers tax authorities have to gather information.
• Practical tips for responding to information requests in both jurisdictions, including how to narrow the scope of requests, manage privilege, and engage proactively with revenue authorities.
• How joint audits work, the specific risks they present, and why appointing a coordinator, or "conductor", of local counsel, is essential.
• The use of the Mutual Agreement Procedure (MAP) to resolve cross-border disputes, including recent case law supporting taxpayer choice between domestic remedies and MAP.  
• Current areas of focus for both the ATO and HMRC, including transfer pricing, hybrid measures, and anti-avoidance rules.

The key message throughout is the importance of early engagement, strategic coordination across jurisdictions, and building a robust defence file while memories are fresh and documents remain available.