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ATO releases revised Practical Compliance Guideline on intangibles arrangements Client Alert

The ATO has released the revised Draft Practical Compliance Guideline PCG 2023/D2, outlining the compliance approach to intangibles arrangements involving international related parties, addressing the tax issues associated with restructures (“migration”) or mischaracterisation of Australian activities in connection with intangible assets.

Christine Cornish
Jason Casas
Keith To
| 4 min read | 23 May 2023
Assessing intangibles for compliance and R&D grant eligibility Insight

In an increasingly digitised global world, technology is omni-present, transcends geographic boundaries, and influences every aspect of 21st century life. With this rapid change, invisible assets, or intangible assets (“intangibles”) are progressively more important value drivers for many Multinational Enterprises (MNEs). These intangibles have become the focus of tax controversy worldwide.

Jason Casas
Christine Cornish
Sukvinder Heyer
Uma Adash
| 9 min read | 15 Mar 2023