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The Tax Institute Submission | Draft Practical Compliance Guideline PCG 2021/D3 ” Imported hybrid mismatch rule ” ATO's compliance approach

Author: The Tax Institute

Published Date: 19 Jul 2021

 

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The Tax Institute welcomes the opportunity to make a submission to the Australian Taxation Office (ATO) in relation to the draft Practical Compliance Guideline PCG 2021/D4, Intangibles Arrangements (Draft PCG).

This submission has been developed in close consultation with a subcommittee of The Tax Institute's members to obtain a breadth of views on issues that impact our broader membership.

We invite the ATO to consider our submission and respectfully request that further action as recommended in this submission is taken to enhance the Draft PCG to ensure clear guidance and practical insight is provided to the community. We have set out below our main concerns in relation to the Draft PCG, in particular:

  • the object and purpose of the Draft PCG, and the extent to which it goes beyond existing guidance relating to transfer pricing; and
  • the onerous documentation and evidence requirements currently required under the Draft PCG, including those requirements having retrospective effect.
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  • Published By:The Tax Institute
  • Published On:19 Jul 2021
  • Session Name:The Tax Institute Submission | Draft Practical Compliance Guideline PCG 2021/D3 ” Imported hybrid mismatch rule ” ATO's compliance approach
  • Read Time:10+ minutes

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The Tax Institute
(ABN 45 008 392 372 (PRV14016))

("TTI")

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