Central management and control test of residency: ATO provides risk assessment framework guidance

The new framework reinforces the need to review the tax residency position and supporting documentation for companies, particularly subsidiaries of Australian groups, as detailed by Peter Oliver, Jenny Wong and Jessica Croker.

The Australian Taxation Office (ATO), on 28 June 2023, released updated guidance Draft Practical Compliance Guideline PCG 2018/9DC1 Central management and control test of residency: identifying where a company’s central management and control is located which updates PCG 2018/9.  Significantly, the updated draft PCG includes a new risk assessment framework to assist foreign-incorporated companies to further understand when their circumstances may be low risk, or when the ATO might apply...

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Authors: Peter Oliver, Jenny Wong,

Published Date: 05 July 2023