Global Daily Tax News, ATO Drafts New TP Guidance On Financing Arrangements, (Jun 19, 2025)

The Australian Taxation Office is currently seeking feedback on new draft guidance on cross-border related-party financing arrangements.

The draft Practical Compliance Guideline ( PCG 2025/D2) outlines the agency's compliance approach and risk assessment framework, providing:

• general factors relevant in determining and testing the valuation of a taxpayer's inbound, cross-border related-party financing arrangements;

• specific examples on how the agency considers these factors in its compliance approach; and

• the types of documentation and evidence expected from taxpayers concerning the pricing of cross-border related-party financing arrangements.