Australia: Final guidance, multinational anti-avoidance provisions (MAAL)

Australia: Multinational anti-avoidance provisions

The Australian Taxation Office (ATO) this week issued a final version of guidelines concerning taxpayer engagements with the ATO in relation to the “Multinational Anti-Avoidance Law” (MAAL) provisions, pursuant to the MAAL “client experience roadmap.”

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The guidelines are an inducement for taxpayers potentially affected by the MAAL provisions to engage with the ATO to discuss the potential application of the tax provisions to particular circumstances. The ATO is offering significant reductions of potential penalties for taxpayers who contact the ATO before 31 March 2016 and engage in discussions with the ATO on how the MAAL provisions may apply.

The ATO has designated five categories of MAAL taxpayers, each with different potential penalties if the MAAL provisions are ultimately determined to apply. 

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Significant incentives are being offered to taxpayers to engage with the ATO as early as possible. The MAAL client experience roadmap further indicates that the MAAL provisions have a much broader scope than originally anticipated, with the number of taxpayers potentially affected by the MAAL provisions being many more than the 30 companies originally targeted. 

 

 

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