02 August 2018

Australian Taxation Office issues draft schedule regarding tax risk classification for cross-border related party derivatives

The Australian Taxation Office (ATO) issued a draft "Schedule 2: Related party derivative arrangements" (the draft schedule) on August 1, to be added to the ATO PCG 2017/4 "ATO compliance approach to taxation issues associated with cross-border related party financing arrangements and related transactions" (PCG). The draft schedule is proposed to apply from January 1, 2019 and sets out 14 specific risk indicators for cross-border related party derivative arrangements that are used to hedge or manage the economic exposure of a company or group of companies. It follows the 2018 release of the PCG, which set out the general ATO approach to risk assessment for cross-border related party financing transactions.

A Global Tax Alert, attached below, provides additional details.

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ATTACHMENT

Document ID: 2018-1558