Source: Taxation In Australia Journal Article
Published Date: 1 Apr 2022
The Commissioner of Taxation issued PCG 2021/4 on 16 December 2021. The guideline is concerned with inappropriate tax outcomes arising from the allocation of profits from professional firms. It is essentially a targeting system, setting out a risk assessment framework by which the Commissioner will judge who within the applicable industries will likely be subject to further analysis and possibly audit, and who will not. Part 1 of this article starts with a brief background on the history of the tax technical matters underlying PCG 2021/4. It then covers the qualifying criteria that must be satisfied in order to rely on the guideline's risk assessment framework, and what happens when they are not satisfied. Part 2 will cover PCG 2021/4's risk assessment framework, the scoring system, and the transitional arrangements with suspended guidelines from 2015.
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