Exposure draft denying deduction for payments attributed to intangible assets issued – 4 April 2023

On 31 March 2023, the Australian Treasury issued draft legislation to introduce an anti-avoidance rule whereby tax deductions for payments attributable to the exploitation of intangible assets made by a significant global entity, directly or indirectly, to an associate in a low corporate tax jurisdiction will be denied. The anti-avoidance rule is to apply to relevant payments made on or after 1 July 2023.

Our latest Tax Insight provides initial observations on the key features of the proposed anti-avoidance rule.