Published on 19 Jul 21
by THE TAX INSTITUTE
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.
The Tax Institute is Australia's leading professional association and educator in tax, with offices in most major cities. Focusing solely on tax, the Institute provides the best resources, education and networks. Our mission is to equip tax professionals with everything they need to demonstrate the highest level of expertise and increase the advancement of public knowledge and understanding.
We are also committed to propelling members into the future and onto the global stage with the introduction of the Chartered Tax Adviser designation.