On 6 November 2020, Australia's Full Federal Court dismissed the Commissioner of Taxation's appeal against the previous decision in favour of Swiss-based trader Glencore Group on all but one issue.
More than 18 months after the publication of its non-consensus discussion draft on Financial Transactions (BEPS Actions 8 – 10) (the DD), the OECD released its ‘final’ guidance on the transfer pricing of financial transactions on Tuesday 11 February 2020.
The Australian Tax Office (ATO) has issued a taxpayer alert to signal its impending scrutiny and concern in relation to mischaracterisation of activities connected to intangible assets.
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 The release of draft guidance PCG 2018/D8 provides the latest ATO framework for inbound distributors to assess their transfer pricing risk.
The ATO has issued draft guidance formalising its view confirming the tax debt equity rules cannot limit the operation of the transfer pricing rules in respect of cross border related party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.