Paul and Filippo discuss a range of issues around the draft Practical Compliance Guidelines (PCG) issued by the Australian Taxation Office, including:
- Why intangibles tend to attract attention from tax authorities
- The context for the new PCG, and the ATO’s approach
- The structure, content and aims of the PCG
- The self-assessment reporting process, and the situations in which this is mandatory
- Examples of the types of arrangements that are likely to attract more scrutiny
- What sorts of evidence taxpayers may need in order to support their TP arrangements
- How other tax authorities’ requirements may develop in the near future
- Australia’s new Multinational Tax Integrity regime
- Key takeaways for groups and their advisers.