The Australian Tax Office (ATO) has issued a roadmap and risk guidelines re: intercompany financing parameters. Taxpayers have an 18-month amnesty period to move their related party financing arrangements to a “green” low-risk zone. EY’s Global Tax Alert provides further details.
Rest of World: All countries watch what other tax administrations are legislating, thus this roadmap/risk rating process may be arising in many other countries. This should be an additional warning signal to multinationals to review such arrangements, as what one considers “arm’s-length” may not be completely nil risk dependent on the legislation of particular countries. Unfortunately, this will lead to additional complexity and probably double taxation consequences.