The ATO published on 16 December 2021 the long-awaited final Practice Compliance Guideline PCG 2021/4 for the allocation of profits by professional firms.

Critically, the start date has been deferred to 1 July 2022, and there is now a 2 year transitional period to 1 July 2024 for arrangements that were low risk under the Suspended Guidelines.

Otherwise, the final PCG is substantially the same as the draft, albeit with more examples as to how the ATO would apply the guidelines, and with some concessions around the risk factors.

The deferred start date provides professional services businesses (management and partners) appropriate time to consider the impact of the PCG on their business structures, remuneration and compliance obligations. We will be publishing information on next steps as developments emerge.

Related content

Webinar - 3 Feb 22

The ATO has finalised the Practical Compliance Guidelines (PCG) for the allocation of profits by professional firms. Now what?

Read more Webinar - 3 Feb 22

Client alert

ATO releases PCG 2021/4: Allocation of professional firm profits

Read more Client alert

Webinar on-demand

Watch our March 2021 webinar on demand: Allocation of profits within professional services firms (DRAFT PCG)

Read more Webinar on-demand

Client alert

Draft PCG 2021/D2: Allocation of profits within professional services firms – what do we know so far?

Read more Client alert

Grant Thornton submission

Grant Thornton submission on Draft PCG 2021/D2 Allocation of professional firm profits – ATO compliance approach

Read more Grant Thornton submission

How we can help

We have significant expertise in the structuring of professional services practices generally and on this specific matter, having authored or contributed to submissions on the draft PCG to the ATO on behalf of clients, professional bodies and on our own behalf.

Please contact us to discuss how we can support your business, including assessing key areas of exposure, implications for existing arrangements, forecast income.

For more information, please contact:

Paul Banister


+61 7 3222 0202

Ben Matthews


+61 2 9286 5732

Yan Wong


+61 8 8372 6609

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