Executive summary
On 19 May 2021, the Australian Taxation Office (ATO) released guidance on Intangibles Arrangements with international related parties in draft Practical Compliance Guideline (PCG) 2021/D4. This represents the latest of the ATO’s transfer pricing-focused PCGs.
The PCG outlines the ATO’s compliance approach and risk factors connected with ”Intangibles Arrangements,” encompassing arrangements connected with the development, enhancement, maintenance, protection and exploitation (DEM…