12 August 2016 Australian Taxation Office issues Taxpayer Alert on restructuring distribution of overseas intangibles and services to Australian customers The Australian Taxation Office issued a Taxpayer Alert on August 10 in relation to arrangements being entered into by certain multinational businesses under which it is argued that certain supplies made by the Australian entity are not "connected with Australia." The main supplies impacted are the distribution of intangibles and services to Australian customers, and may involve the use of a non-Australian entity purporting to be the agent of the Australian principal. The TA is not formally binding ATO advice, but serves as an ATO warning to MNEs involved in these activities to seek independent advice in relation to their positions, to highlight ATO compliance action with potential penalty exposures, and to prepare for ATO examination of the issues and to be aware of the ATO's willingness to contest the issues. Document ID: 2016-1393 |