ATO targets international profit-shifting arrangements
The Australian Taxation Office (ATO) released four Taxpayer Alerts in April as a result of the ATO actively reviewing certain arrangements used by multinationals and large companies operating in Australia.
The four Taxpayer Alerts address the following:
- TA 2016/1: Inappropriate recognition of internally generated intangible assets and revaluation of intangible assets for thin capitalisation purposes
- TA 2016/2: Interim arrangements in response to the Multinational Anti-Avoidance Law (MAAL)
- TA 2016/3: Arrangements involving related party foreign currency denominated finance with related party cross currency interest rate swaps
- TA 2016/4: Cross-border leasing arrangements involving mobile assets.