New draft risk guidance for outbound interest-free loans

Tim Keeling and Frank Putrino discuss the ATO’s draft Schedule 3 contained in PCG 2017/4DC2 – interest-free loans between related parties.

The Australian Taxation Office (ATO) has released its long-awaited draft risk-guidance relating to outbound interest-free loans made between an Australian taxpayer and its international related parties.The ATO’s draft Schedule 3 contained in PCG 2017/4DC2 – interest-free loans between related parties provides updated guidance regarding key factors to consider when determining the transfer pricing risk of outbound interest-free debt lent by Australian taxpayers to international related parties...

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Authors: Tim Keeling, Frank Putrino

Published Date: 13 August 2020