Australia: ATO compliance approach to the arm’s length debt test
On 28 August 2019, the Australian Taxation Office (ATO) published draft Practical Compliance Guideline PCG 2019/D3, which sets out the proposed compliance approach for the use of the arm’s-length debt test (ALDT) for the purposes of
See MoreAustralia issues final PCG and ruling on hybrid mismatch rules
The Australian Taxation Office has issued Practical Compliance Guideline (PCG) 2019/6 and Law Companion Ruling (LCR) 2019/3, related to the concept of structure arrangements in relation to Australia's new hybrid mismatch rules.
See MoreAustralia introduces a bill to amend thin capitalization rules
On 4 July 2019, the Treasury Laws Amendment (Making Sure Multinationals Pay Their Fair Share of Tax in Australia and Other Measures) Bill 2019 was introduced in the Australian House of Representatives. The purpose of the Treasury Laws
See MoreAustralia provides additional 15 days for CbC statement lodgment
The Australian Taxation Office (ATO) has provided additional 15 days for the lodgment of CbC statements (Local File, Master File, CbC report) with 30 June 2019 due date because of technical issues. This additional time will apply automatically
See MoreAustralia issues draft ruling on thin capitalization
On 5 April 2019, the Australian Taxation Office (ATO) released a draft ruling TR 2019/D2 with respect to the requirements for the application of the arm’s-length debt test (ALDT) in the thin capitalization rules. The draft ruling proposes that
See MoreAustralia: Federal Budget 2019-20
On 2 April 2019, the Australian Government announced its 2019-20 Budget. The Government is lowering taxes for working Australians and backing small and medium‑size business, while ensuring all taxpayers, including big business and multinationals,
See MoreAustralia: New guidance related to inbound distribution arrangements
On 13 March 2019, the Australian Taxation Office (ATO) released a PCG 2019/1 for all multinational enterprises (MNEs) with distribution operations in Australia. This Guideline outlines compliance approach to the transfer pricing
See MoreAustralia: ATO updates guidelines of STPRK options
The Australian Taxation Office (ATO) has recently updated Practical Compliance Guideline (PCG) 2017/2 Simplified transfer pricing record-keeping (STPRK) options. The PCG outlines transaction types or activities identified as low risk for
See MoreAustralia: ATO extends deadline to file CbC reports
Significant Global Entities (SGE) that have a Country-by-Country (CbC) reporting obligation for the year ended 31 December 2017 will be aware that the Local file, Master file, and CbC report are due to be lodged by 31 December 2018. However, due
See MoreAustralia: ATO implements the OECD hybrid mismatch rules
In the 2016–17 Budget, the Australian government announced it would implement the Organisation for Economic Cooperation and Development (OECD) hybrid mismatch and branch mismatch rules from Action Item 2 of the OECD Base Erosion and Profit
See MoreAustralia updates MAP guidance
The Australian Taxation Office (ATO) has updated its guidance on the mutual agreement procedure (MAP) framework contained in tax treaties to resolve disputes. The new guidance represents an update on Taxation Ruling TR 2000/16 Income tax:
See MoreAustralia: ATO publishes Diverted profits tax guidance
The Australian Tax Office (ATO) published the final form of the Practical Compliance Guideline (PCG) 2018/5 Diverted profits tax (DPT) and Law Companion Ruling (LCR) 2018/6 Diverted profits tax. The PCG aims to assist affected clients and their
See MoreAustralia: Eligibility changes for the lower corporate tax rate
Changes to the lower corporate tax rate are now law. This means the definition of a base rate entity has changed by replacing the 'carrying on a business' requirement with a passive income test. From the 2017–18 income year, a corporation will be
See MoreAustralia: Parliament adopts hybrid mismatch legislation
On 16 August 2018, Treasury Laws Amendment (Tax Integrity and Other Measures No. 2) Bill 2018 containing the hybrid mismatch integrity measures was passed by the Parliament. The bill includes the measures to prevent entities that are liable to
See MoreAustralia: ATO issues draft schedule concerning cross border related party financing arrangements
On 1 August 2018, the Australian Taxation Office (ATO) issued a draft Schedule 2 to PCG 2017/4 for public consultation. This guidance addresses the ATO’s compliance approach to taxation issues associated with cross border related party
See MoreAustralia: Improving the integrity of the thin capitalization rules
The Australian Government announced that it will implement two changes to improve the integrity of Australia’s thin capitalization rules in the 2018-19 Budget. The changes are: requiring entities to align the value of their assets for thin
See MoreAustralia: New guidelines for Local and Master file for 2018
The Australian Taxation Office (ATO) has published Local file instructions 2018 and Local file/master file 2018 to provide guidance for taxpayers to comply. The local file must be electronically lodged in the approved form (an XML file generated
See MoreAustralia: ATO publishes draft guidance on transfer pricing issues
The Australian Taxation Office (ATO) has issued Draft Schedule 2 to Practical Compliance Guideline (PCG) 2017/1 ATO compliance approach to transfer pricing issues related to centralized operating models involving procurement, marketing, sales and
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