Australia: 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See MoreAustralia: ATO publishes draft guidance on transfer pricing issues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
See MoreAustralia: Draft PCG for Restructures of Hybrid Mismatch Arrangements
As part of the 2016-17 Federal Budget, the Australian government announced it would implement the Organisation for Economic Co-operation and Development's (OECD) Hybrid Mismatch rules developed under Action Item 2 of the OECD Base Erosion and Profit
See MoreAustralia updates international dealings schedule for 2018 tax year
The Australian Taxation Office (ATO) has released the 2018 International dealings schedule (IDS) and their instructions for 2018 tax years. The IDS must be lodged by businesses that provide a response at the trigger questions of the relevant
See MoreAustralia updates guidance on R&D tax offsets
The Australian Taxation Office (ATO) has published updated guidance concerning the rate of the Research and Development (R&D) tax offset and whether it is refundable under the R&D tax incentive. If aggregated turnover is less than AUD
See MoreAustralia: Federal Budget 2018
On 8 May 2018, the Commonwealth Treasurer, Mr. Scott Morrison, announced the Federal Budget 2018-19. Mr. Morrison said “in this year's Budget there are five things we must do to further strengthen our economy to guarantee the essentials
See MoreAustralia: ATO announces CbC reporting deadline for local file
The Australian Taxation Office (ATO) has released its final draft of the 2018 Message Structure Table (MST) and XML Schema for the Australian Local File (ALF) for tax year 2018. This will represent the second ALF that most taxpayers will be required
See MoreAustralia: Deadline for R&D Registration
The Research and Development (R&D) Tax Incentive registration deadline for those companies with a 30 June 2017 year end is rapidly approaching. The statutory deadline for lodging an application is 10 months after the end of the income year; for
See MoreAustralia: Minimum interest rate for simplified transfer pricing record keeping for 2018
The Australian Taxation Office (ATO) has updated its guidance on simplified transfer pricing record keeping options to include the minimum interest rate for the simplified option for low-level outbound loans for the 2018 income year, which is set at
See MoreAustralia introduces Treasury Laws Amendment (OECD MLI) Bill 2018
On 28 March 2018, the Australian Government introduced Treasury Laws Amendment (OECD Multilateral Instrument) Bill 2018 (the MLI Bill) into Parliament, together with a detailed explanatory memorandum. The MLI bill will need to be passed by the House
See MoreAustralia: Closing tax consolidation loopholes
On 22 March 2018, the Australian Government’s commitment to ensure multinationals pay the right amount of tax in Australia continued with the passage through Parliament of the Treasury Laws Amendment (Income Tax Consolidation Integrity) Bill
See MoreAustralia: Implementing the OECD Hybrid Mismatch Rules
The Australian Government announced in the 2016-17 and 2017-18 Budgets that it would implement the Organisation for Economic Co operation and Development’s (OECD) rules aimed at eliminating double non-taxation benefits from hybrid mismatch
See MoreAustralia: ATO releases draft PCG on diverted profits tax
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
See MoreAustralia: Guidelines on attribution of ADI equity capital and controlled foreign entity equity
On 24 January 2018, the Australian Taxation Office (ATO) issued the Practical Compliance Guideline (PCG) 2018/1. This Guideline sets out how the ATO will administer subsection 820-300(3) of the Income Tax Assessment Act 1997 (ITAA
See MoreAustralia: Final guideline on cross-border related-party financing arrangements
The Australian Taxation Office (ATO) has published the final Practical Compliance Guideline PCG 2017/4 on its compliance approach to cross-border related financing arrangements. The guidance explains how taxpayers can price related party loans to
See MoreAustralia: New guidance on DPT
On 18 December 2017, the Australian Taxation Office (ATO) published a draft law companion guideline (LCG) 2017/D7 on Diverted profits tax (DPT) for public consultation. The draft Guideline addresses Schedule 1 to the Treasury Laws Amendment Act 2017
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