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ATO issues final risk guideline on Intangibles migration arrangements

13/02/2024

The Practical Compliance Guideline (PCG) 2024/1 (the Guideline) has been released with ATO poised to dedicate resources towards scrutinising cross-border related party intangible arrangements. As a result taxpayers will face increased disclosure and self-evidence requirements. After a nearly three-year wait[1], the ATO finalised the risk guideline targeting cross-border related party arrangements (collectively referred to as […]

Ampol settles ATO tax dispute over offshore procurement hub: Key takeaways for transfer pricing compliance

07/03/2023

Ampol Limited, formerly Caltex Australia, has settled a transfer pricing dispute with the Australian Taxation Office (ATO) for $157 million. Ampol Group (Ampol) is an Australian energy company that operates in the fuel and convenience retail sector. Its subsidiaries in Singapore (Ampol Singapore) serve as a trading and shipping arm of the group, sourcing refined […]

Leo Luan, Partner

23/11/2021

I have more than 15 years of experience providing tax services to multinational and domestic businesses. I have extensive experience in mergers and acquisitions, tax structuring, tax consolidation, and cross-border financing across a range of industries, including natural resources, property, and agriculture. I advise a wide range of clients, including state-owned entities, publicly listed groups, […]

Andy Lau, Partner

03/11/2021

I have extensive experience providing accounting, taxation, and business advisory services to a broad range of clients, from high-net-worth individuals to large private businesses and subsidiaries of foreign multinationals. I regularly assist foreign businesses and investors entering the Australian market, providing initial structuring and setup advice, strategic tax planning, ongoing operational advice, and fully outsourced […]