Strategizing International Tax Best Practices – by Keith Brockman

Posts tagged ‘intercompany financing’

Financing risk roadmap: ATO

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.  

http://www.ey.com/Publication/vwLUAssets/Australian_Taxation_Offices_compliance_approach_for_cross-border_related_party_financing_arrangements_has_major_impact_on_multinational_businesses/$FILE/2017G_03234-171Gbl_TP_AU%20TOs%20compliance%20approach%20for%20cross-border%20related%20party%20financing%20arrangements.pdf

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