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ATO issues final risk guideline on Intangibles migration arrangements

13/02/2024

The Practical Compliance Guideline (PCG) 2024/1 (the Guideline) has been released with ATO poised to dedicate resources towards scrutinising cross-border related party intangible arrangements. As a result taxpayers will face increased disclosure and self-evidence requirements. After a nearly three-year wait[1], the ATO finalised the risk guideline targeting cross-border related party arrangements (collectively referred to as […]

ATO draft guidance on Intangibles Arrangements between related parties

01/06/2021

The Australian Taxation Office released draft Practical Compliance Guideline 2021/D4 on 19 May 2021 (Draft PCG), outlining how international arrangements connected with the development, enhancement, maintenance, protection, and exploitation (DEMPE) of intangible assets and/or migration of intangible assets (Intangibles Arrangements) will be assessed. Intangibles Arrangements is the long-awaited and last tranche of ATO’s focus areas […]