Episode 12: Transfer pricing aspects of intangibles, with Filippo Miotto

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.
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