The ATO’s Draft Guidance on Inbound Financing – A Welcome Framework, but Real-World Complexities Remain.
September 18, 2025
The Australian Taxation Office (ATO) has taken a significant step in shaping its approach to transfer pricing compliance with the recent release of Draft Practical Compliance Guideline PCG 2025/D2, addressing the tax risks associated with the amount of inbound, cross-border related party financing arrangements. Released in response to legislative reforms
