On 18 December 2017, the Australian Taxation Office (ATO) published a draft Law Companion Guideline on Diverted Profits Tax (LCG 2017/D7) for consultation. The draft Guideline addresses Schedule 1 to the Treasury Laws Amendment (Combating Multinational Tax Avoidance) Act 2017 (the Act), which introduced a Diverted Profits Tax (DPT) at a rate of 40% that will be imposed on profits that have been artificially diverted from Australia by significant global entities (members of MNE groups with glo…