The taxation of intangible assets is a complex area of taxation
and further complexity is added where there are international
related party dealings in respect to these assets. Significant
legislative and interpretative changes are being made in relation
to the taxation of intangibles which impact taxpayers.
The taxation of international related party intangible
arrangements is further under the scrutiny of the Australian
Taxation Office (ATO) following the release of
draft Practical Compliance Guideline (PCG)
2021/D4. PCG 2021/D4 sets out the ATO's compliance approach to
international arrangements connected with the development,
enhancement, maintenance, protection, and exploitation of
intangible assets and/or involving a migration of intangible
assets.
