Significant expansion of Australia’s general anti-avoidance rule in Part IVA – what does this mean for multinationals?

Taxpayers should review all of their historical, existing and prospective cross-border arrangements and ensure they are ATO-ready, as outlined by Angelina Lagana, Keith Swan, Denis Larkin and Peter Oliver.

As part of the tax measures contained in the 2023 Federal Budget, the Government will expand the scope of the general anti-avoidance rule for income tax (contained in Part IVA of the Income Tax Assessment Act 1936 (Cth)) so that it applies to any transaction that results in: less tax being paid in Australia where the arrangement allows taxpayers to access lower withholding tax rates on payments made to foreign residents; and taxpayers accessing Australian income tax benefits, even where t...

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Authors: Angelina Lagana, Keith Swan,

Published Date: 10 May 2023