The ATO has released draft Practical Compliance Guideline PCG 2017/D4 (Guidelines) which apply from 1 July 2017 to new and existing cross-border financing arrangements between related parties. The Guidelines allow taxpayers to self-assess the risk level of their financing arrangements to determine the likelihood of an ATO review. As part of the Guideline, the ATO has offered a limited-period amnesty for taxpayers looking to de-risk their financing arrangements without penalties and interest.

For further details, see New ATO guidance on related party cross-border financing arrangements: new amnesty announced dated 24 May 2017.