Australia: ATO issues guidance on loss carry back tax offset
The Australian Taxation Office (ATO) published guidance on the loss carry back offset relief introduced as part of measures for the 2020-21 Budget. Loss carry back provides a refundable tax offset that eligible corporate entities can
See MoreAustralia: ATO releases final guidance on related party loan
On 10 December 2020, the Australian Taxation Office (ATO) issued final transfer pricing guidance on interest-free loans between related parties, in “Schedule 3 – Interest-free loans” to the ATO’s financing Practical Compliance Guideline
See MoreAustralia updates APA guidance
On 3 December 2020, the Australian Taxation Office (ATO) published an updated law administration practice statement about the advance pricing arrangements (APA) program. The updated guidance (PS LA 2015/4) reflects changes to the APA
See MoreAustralia: ATO declares lodgment deferral for Local File, Master File, and CbC Report for FY 2019
The Australian Taxation Office (ATO) has issued a notice declaring a lodgment deferral for the Local file, Master file, and Country-by-Country (CbC) report for the year ended 31st December 2019. Significant Global Entities (SGEs) that have
See MoreAustralia: Federal Court rules on tax position of UK citizen in Australia with a Working Holiday Visa
In a judgment of 6 August 2020 the Australian Federal Court ruled in favour of the Commissioner of Taxation in a case involving the residency test for a UK citizen staying in Australia on a Working Holiday Visa (WHV). The Court found that the UK
See MoreAustralia: Guidance on Anti-abuse rules in tax treaties
On 12 October 2020, Australian taxation office (ATO) release new guidance about the general anti-abuse rules in any of Australia's tax treaties has been finalized and published. Law Administration Practice Statement PS LA 2020/2 Administering
See MoreAustralia: Parliament approves Federal Budget for 2020-21
On 9 October 2020, Mr. Scott John Morrison, the Prime Minister of Australia has issued a release announcing the approval of the Budget 2020-21 measures. On 6 October 2020, the Budget measures were included as part of the Treasury Laws Amendment
See MoreAustralia: ATO clarifying the operation of hybrid mismatch rules
Australia's hybrid mismatch rules have been updated with a number of technical amendments in order to clarify and improve the rules' operation. In the 2019–20 Budget on 2 April 2019, the Australian government announced the measure Tax
See MoreAustralia: ATO finalized guidance on the arm’s length debt test
On 12 August 2020, the Australian Taxation Office (ATO) released its finalized practical guidance dealing with the application of the arm’s length debt test (ALDT) which applies as one of the options for determining deductibility of interest and
See MoreAustralia updates transfer pricing legislation in accordance with OECD guidelines
Australia's transfer pricing legislation has been updated to specify that it is to be interpreted to achieve consistency with the Organisation for Economic Co-operation and Development (OECD) Transfer Pricing Guidelines for Multinational
See MoreAustralia: Integrity rule law companion ruling finalized
In April 2019, Australian Taxation Office (ATO) released a draft Law Companion Ruling on the Organization for Economic Cooperation and Development (OECD) hybrid mismatch rules related to integrity rule. The ATO have now released draft LCR
See MoreAustralia reduces tax rates for small businesses
Mr. Josh Frydenberg, the Australian Treasurer has issued a joint release on the reduction of the corporate income tax rate for businesses with turnover of less than AUD 50 million. From July 1 2020, small and family businesses will be paying less
See MoreAustralia updates instructions for local file 2020
The Australian Taxation Office (ATO) updated the instructions for local file. These instructions apply to the local file for 2020. This relates to reporting periods starting on or after 1 January 2019. According to the instructions, local file
See MoreAustralia: Guidance on the Impact of the COVID-19 Crisis on Transfer Pricing Arrangements
On 19 June 2020 the Australian Taxation Office (ATO) posted to its website guidance entitled COVID-19 economic impacts on transfer pricing arrangements. This sets out guidance for taxpayers affected by COVID-19 who are preparing transfer pricing
See MoreAustralia extends provision for instant asset write-off
On 9 June 2020, Australia’s federal government further announced plans to facilitate small business in response to the Covid-19 surge. That government will extend the AUD 150,000 instant asset write-off for six months to 31 December
See MoreAustralia updates guidelines for resolving international tax disputes
The Australian Taxation Office (ATO) has updated the guidelines for the mutual agreement procedure (MAP) and arbitration arrangements. The updated guidelines reflect modifications made (or to be made) in some of Australia’s tax treaties made
See MoreAustralia: ATO concerns over mischaracterized financial arrangements
On 25 May 2020, the Australian Taxation Office (ATO) issued Taxpayer Alert (TA) 2020/2, in relation to mischaracterised arrangements and schemes connected with direct foreign investment into Australian businesses. ATO is concerned that
See MoreAustralia: New proposals on Hybrid mismatch rule
On 13 May 2020, the Treasury Laws Amendment Bill 2020 was presented in the House of Representatives that would make technical changes to the hybrid mismatch rules addressing integrity of income tax laws and their application to multinational
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