Non-deductibility of payments relating to intangible assets

On 31 March 2023, Treasury released Exposure Draft legislation (Draft Bill) that introduces a new anti-avoidance provision aimed at denying deductions for payments made by Significant Global Entities (SGEs) in relation to intangible assets connected with low tax jurisdictions. This is consistent with The Federal Government’s broader strategy to address key concerns regarding the taxation of multinational groups.

In response, BDO has prepared a submission outlining several issues of concern in the Exposure Draft legislation including the broad application of the proposed measures and the wide definition of ‘low or nil taxed jurisdiction’.


Should have any questions regarding the content of this submission, please contact your BDO tax adviser for further guidance.