Australia is preparing to target companies with risky intangible asset arrangements via guidance released Wednesday.
To ensure companies meet general anti-avoidance and transfer pricing rules, the Australian Tax Office is targeting corporate arrangements that specifically migrate intangible assets and incorrectly characterize Australian activities to enhance assets, according to the document.
- Some risk factors for intangible asset arrangements include whether the taxpayer changed who has access to the asset arrangements, the level of substance of entities that have access to the arrangements, and the tax benefits linked to the arrangements, such as R&D credits.
- Taxpayers will be required to ...
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