Related Party Financing
Cross border related party financing arrangements and related transactions (collectively, financing arrangements) are of particular investigative focus for the Australian Taxation Office (ATO).
This calculator provides a risk rating for your financing arrangements and guidance on the likely approach of the ATO to allocating its compliance resources to reviewing and auditing your financing arrangements.
This calculator is also suitable for foreign investors who are required to make Foreign Investment Review Board (FIRB) applications. FIRB often requires applicants to disclose the risk rating for new and existing financing arrangements.
INSTRUCTIONS FOR USING THIS CALCULATOR
This calculator is optimised for Google Chrome and Firefox and in landscape desktop format.
Enter the calculator by answering the three questions below.
You will then be taken to the Check-In section which will guide you through some preliminary questions to determine whether this calculator will provide you with useful and appropriate results.
Once you have been through the Check-in section, you will enter either the Inbound Financing or Outbound Financing sections based on your answers.
An ADI is supervised by the Australian Prudential Regulation Authority and authorised under the Banking Act 1959 (Cth) to accept deposits from the public.
Broadly, a securitisation vehicle is established for acquiring, funding and holding certain assets that are acquired from another entity and funded by issuing debt interests by the vehicle. Section 820-39 of theIncome Tax Assessment Act 1997 (Cth) applies to certain insolvency remote special purpose entities that are established for the purposes of managing some or all of the economic risks associated with assets, liabilities or investments.
The ATO permits certain taxpayers to use simplified transfer pricing record keeping options as an administration and cost saving measure where the taxpayer and its activities are likely to be low risk. A taxpayer's eligibility is set out in Practical Compliance Guideline PCG 2017/2.
Using the calculators
You must answer every question in the relevant section; otherwise, a risk rating will not be available.
Each question contains a heading, a brief description and an answer scale (which contains a sliding scale, a yes/no switch, or both). Detailed information on each question can be obtained by clicking on the ? symbol on the top left corner of the question box.
Once all of the questions have been completed, you will be prompted to provide your details. Once done, click on the final button to get your risk rating.
Why do we ask for your details and how do we use your information? Although we provide this calculator free for your use, it is important to us to ensure the results are meaningful. We manually review the information you have provided to see if we can give you further observations that may be useful. We also collate aspects of your information to ascertain patterns based on taxpayer profiles, that may also be useful to you. We will contact you using your details if we can provide such assistance.
We also use your details to e-mail you a copy of your risk rating.
We do not disclose your information or details to any person, unless required by a law.
We will automatically remove personal details from any information we retain within 6 months of you using the calculator, unless you have engaged us to provide advice.
Our liability to you We disclaim any liability to you. We have tested the calculators and ensured they align with the ATO's guidelines in PCG 2017/4. However, the risk rating is a function of your inputs. We do not review your financing arrangements (unless you separately engage us to do so) and cannot confirm whether your inputs are correct or appropriate. Even if your inputs are correct, the ATO may choose to treat your financing arrangements as higher risk than indicated by the calculator or otherwise review and audit you.