International Intangibles Arrangements: Documentation, documentation and more documentation – 19 May 2021 has been saved
International Intangibles Arrangements: Documentation, documentation and more documentation – 19 May 2021
On 19 May 2021, the ATO published the highly anticipated draft Practical Compliance Guideline 2021/D4 on ‘Intangibles Arrangements’.
The draft PCG sets out the ATO’s compliance approach to international arrangements connected with the development, enhancement, maintenance, protection and exploitation (DEMPE) of intangible assets and/or involving the migration of intangible assets. The draft PCG is designed to focus on ‘tax risks’ associated with the potential application of Australia’s provisions regarding transfer pricing, withholding tax, Capital Gains tax, capital allowances, the General Anti-Avoidance Rule, and the Diverted Profits tax.