International transactions

Cross-border financing arrangements involving non-arm's length terms or conditions attract our attention.

International arrangements that don't recognise or incorrectly characterise intangible assets attract our attention.

Australian entities who fail to report or incorrectly report attributable foreign income attract our attention.

Entities that do not comply with or incorrectly apply the thin capitalisation rules attract our attention.

Income not subjected to domestic tax due to non-arm's length conditions of international related party dealings.

Entities that fail to withhold tax on interest, dividend or royalty payments to foreign residents attract our attention.

Overseas branch or permanent establishment income incorrectly recognised as NANE branch income attracts our attention.

Cross-border arrangements that mischaracterise inbound foreign funds attract our attention.

Disposals of taxable Australian property by foreign residents attract our attention.

Understand what other issues or arrangements attract our attention.

Hybrid mismatch arrangements which exploit differences in the laws of 2 or more tax jurisdictions attract our attention.

Entities that met the definition of SGE or CBC reporting entity but failed to self-assess as one attract our attention.