Executive summary
On 12 August 2020, the Australian Taxation Office (ATO) released long awaited draft guidance on outbound interest-free financing between cross-border related parties in Practical Compliance Guideline (PCG) 2017/4DC2. The draft guidance is added within a new schedule to PCG 2017/4 (the PCG); draft Schedule 3 (the draft Schedule).
The draft Schedule outlines the ATO’s views on factors that may be considered to risk score an outbound interest-free loan arrangement, that otherwi…