The Australian Taxation Office (ATO) has published a draft Practical Compliance Guideline (PCG 2017/D4) concerning the ATO compliance approach to taxation issues associated with cross-border related party financing arrangements and related transactions. The Guideline provides a framework for taxpayer's to:
- Assess the tax risk of their related party financing arrangement in accordance with the ATO's risk framework; and
- Understand the compliance approach the Commissioner is likely to adopt giv…