13 Mar 15
ATO Division 815 Working Group
On 26 February 2015, Damian Preshaw CTA (KPMG) attended a meeting of the ATO Division 815 Working Group. Key matters arising at the meeting included:
- Potential expansion of simplification measure in relation to outbound interest-free loans
- The remit of the working group
- Recent developments in relation to Advance Pricing Arrangements
- PS LA 2015/3 on exceptions to the basic rule in section 815-130
- Proposed taxation ruling on consequential adjustments under s815-145
- Proposed practice statement dealing with the calculation of penalties where Subdivision 815-A is applied retrospectively
- ATO evaluation of the International Dealings Schedule and Instructions
- Whether rulings in relation to Division 13 apply in relation to the new transfer pricing law
- ATO response to the Inspector-General of Taxation’s recommendation on publication of benchmarks
- Proposed ATO interpretive products to address matters discussed in TR 92/11 and TR 2010/7 in the context of the new transfer pricing rules.
- Satisfying the eligibility criteria for the simplification measures and how those measures operate on a loan with a non-arm’s length interest rate.
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