Page 19 - BHP Economic Contribution Report 2020

Our approach

Our payments

Tax disputes Reconciling this Report with ATO transparency data Our contribution
Given the size, geographic scope and complexity of our We prepare a reconciliation of our taxes paid in Australia to the
Additional information
operations and, at times, uncertainty regarding the application data published by the ATO each year under Australian mandatory
of taxation laws, we have occasional disagreements with tax corporate tax transparency measures. This reconciliation is
authorities over the amount of taxes to be paid. In this respect, published on our website when the ATO publishes its data.
BHP is no different from other large and complex corporations. The latest data published by the ATO relates to FY2018.
As set out in note 6 ‘Income tax expense’ in section 5 in the Our reconciliation of our Australian taxes paid to this data
Annual Report 2020, we disclose our significant uncertain tax is available on our website at bhp.com.
and royalty matters, including disputes.
Where possible, we engage with revenue authorities on
a real-time basis regarding the application of the tax law and
to identify and resolve any disagreements on a timely basis.
In March 2020, a dispute with the ATO was resolved as a result
of a decision by the High Court of Australia on a technical area
of Australia’s federal income tax rules that impacts the taxation
of certain profits of our Singapore Sales and Marketing business,
(refer earlier Our Sales and Marketing business section).
The decision clarifies that BHP Group Limited and BHP Group
Plc are ‘associates’ for certain Australian income tax purposes
and therefore, profits made by BMAG from the sale of our
Australian commodities acquired from entities controlled by
BHP Group Plc are also taxed in Australia at the corporate tax
rate of 30 per cent. Together with the settlement of the transfer
pricing dispute in FY2019, this decision provides certainty for
both the ATO and BHP regarding the taxation treatment of our
Singapore Sales and Marketing business for future years.

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