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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. 

 Members seeking further information on the above should contact us at