The Australian Taxation Office (ATO) has published a revised version of the Draft Practical Compliance Guideline for Intangible Arrangements (PCG 2023/D2) for consultation. An initial version of the guideline was consulted on in the summer of 2021.
The main changes between the initial and revised versions of the guideline concern the risk assessment framework. In the initial guideline, a general risk assessment framework was provided, while in the revised guideline, two separate framework ta…