BDO submission - Draft guidance on cross-border related party financing arrangements - PCG 2025/D2
BDO submission - Draft guidance on cross-border related party financing arrangements - PCG 2025/D2
Submission
Published:
The Australian Taxation Office (ATO) has released its draft Practical Compliance Guideline (PCG) 2025/D2 - Factors to consider when determining the amount of your inbound, cross-border related party financing arrangement - ATO compliance approach.
The proposed PCG introduces a risk assessment framework and outlines key factors that may influence the ATO’s view of a taxpayer’s capital structure, including leverage ratios, parental guarantees, and documentation standards.
BDO is pleased to respond to the invitation by the ATO, providing our recommendations on the draft PCG 2025/D2.
If you would like further information or support regarding the draft guidance, contact your local BDO adviser from our transfer pricing team.