Practical Compliance Guideline PCG 2017/4DC2 - Draft Schedule 3 - (ATO compliance approach to taxation issues associated with cross-border related party financing arrangements and related transactions)
The submission to the Australian Taxation Office in response to draft Schedule 3 of PCG 2017/4DC2 ATO compliance approach to taxation issues associated with cross-border related party financing arrangements and related transactions (Schedule 3) was prepared by the Taxation Committee of the Business Law Section of the Law Council of Australia.
As a preliminary and general observation, the inclusion of Schedule 3, and the additional guidance in relation to cross-border outbound interest-free loans, is a welcome addition. As follows, the Committee provides its observations on several specific issues, which it considers warrant further consideration in relation to Schedule 3. Please note that this not intended to be a comprehensive response to Schedule 3, nor in relation to PCG 2017/4 generally.
You can read the full submission below.