Peter Madden and Fabian Fedele discuss the ATO's finalised guidance on the Diverted Profits Tax (DPT).
The Australian Taxation Office (ATO) has finalised its guidance on the Diverted Profits Tax (DPT) with the release of both the DPT Practical Compliance Guideline (PCG 2018/5) and Law Companion Ruling (LCR 2018/6).
The finalised guidance addresses a number of the issues raised during consultation, clarifying how key elements of the DPT will be interpreted and more broadly how the ATO will apply the new measure. This includes:
Furthermore, a particularly interesting aspect of the finalised PCG is the addition of a risk assessment tool, which provides a framework for taxpayers to self-assess their DPT risk.
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