BHP has reached an agreement with the Australian Taxation Office (ATO) to settle the transfer pricing dispute relating to its marketing operations in Singapore.
The settlement fully resolves the longstanding dispute between BHP and the ATO for all prior years, being 2003 to 2018, with no admission of tax avoidance by BHP, and provides certainty in relation to the future taxation treatment.
The dispute related to the amount of Australian tax payable as a result of the sale of BHP's Australian commodities to BHP's Singapore marketing business.
As part of the settlement, BHP will pay a total of approximately A$529 million in additional taxes for the income years 2003 to 2018. BHP has already paid A$328 million of this amount, following receipt of amended tax assessments and in accordance with the ATO's normal practice.
In addition, from July 2019, BHP Group Limited will increase its ownership of BHP Billiton Marketing AG, which is the main company conducting BHP's Singapore marketing business, from 58 per cent to 100 per cent. The change in ownership will result in all profits made in Singapore in relation to the Australian assets owned by BHP Group Limited being fully subject to Australian tax.
https://www.investegate.co.uk/bhp-billi ... 00037316H/