On 7 February 2018, the Australian Taxation Office (ATO) publicly released a draft practical compliance guide PCG 2018/D2 concerning Diverted Profits Tax (DPT).
The draft PCG has been released for public consultation and submissions close on 9 March 2018.
The DPT only applies to SGEs. An entity is an SGE for an income year if it is:
- A global parent entity with an annual global income of A$1 billion or more
- A member of a group of entities (consolidated for accounting purposes) where the global parent entity has an annual global income of A$1 billion or more.
For the purposes of the DPT, this definition includes both:
- Australian-headquartered entities with foreign operations
- The local operations of foreign headquartered multinationals.
If global financial statements have not been prepared for the global parent entity, the Commissioner may make a determination that based on information available to him, the annual global income of the entity would be A$1 billion or more for the period.
