The Australian Taxation Office has issued Taxpayer Alert (TA) 2018/2 - Mischaracterisation of activities or payments in connection with intangible assets.
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We are currently reviewing international arrangements that mischaracterise intangible assets and/or activities or conditions connected with intangible assets.
Our concerns include whether intangible assets have been appropriately recognised for Australian tax purposes and whether Australian royalty withholding tax obligations have …