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On 28 August 2019, the Australian Taxation Office (ATO) issued Draft Practical Compliance Guideline 2019/D3 – ATO compliance approach to the arm’s length debt test (the PCG), which provides a risk assessment framework outlining the ATO’s compliance approach to the application of the Arm’s Length...
On 5 April 2019, the ATO released draft Taxation Ruling 2019/D2 – Income tax: thin capitalisation – the arm’s length debt test (“draft ruling”). The draft ruling sets out the ATO’s view as to how the legislative provisions of the arm’s length debt test (“ALDT”) contained in the thin...
The ATO has released an updated version of Practical Compliance Guideline PCG 2017/2, its guidance on simplified transfer pricing record-keeping options, which significantly changes the eligibility criteria for access to the simplified transfer pricing record-keeping options.
The ATO is focusing on Australian taxpayers who distribute goods or digital products/services acquired from related foreign entities. The release of draft guidance PCG 2018/D8 provides the latest ATO framework for inbound distributors to assess their transfer pricing risk.
The ATO has issued draft guidance formalising its view confirming the tax debt equity rules cannot limit the operation of the transfer pricing rules in respect of cross border related party funding.
The Australian Tax Office (ATO) guidance issued in relation to the Diverted Profits Tax (DPT) will be a useful practical tool for taxpayers and it comes nearly a year after the DPT was introduced.
Building on the Australian Taxation Office’s (ATO) success in the Chevron Australia decision, the ATO continues its scrutiny and focus on cross-border financing arrangements. The release of the final version of Practical Compliance Guideline 2017/4 (PCG) provides an insight into the ATO’s...
On 18 December 2017, the Australian Taxation Office (ATO) published documents providing guidance on the application of Diverted Profits Tax (DPT).
The Diverted Profits Tax (DPT) legislation received Royal Assent on 4 April 2017, with Schedule 1 to the Treasury Laws Amendment (Combating Multinational Tax Avoidance) Act 2017 implementing the DPT and Diverted Profits Tax Act 2017.