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Allocation of professional firm profits: part 2
Published on 01 May 22 by "TAXATION IN AUSTRALIA" JOURNAL ARTICLE
Part 1 of this article was prefaced with the longstanding dichotomy between income derived from property and income derived from an individual’s personal services. This formed the background leading to the Commissioner of Taxation issuing PCG 2021/4, concerned with professional firm profits possibly being insufficiently attributed to practitioners whose personal efforts contributed to the derivation of the profit. Part 1 went on to cover when an affected taxpayer qualifies to rely on PCG 2021/4, and their situation when they don’t. In part 2, we move on to PCG 2021/4’s risk assessment framework, the scoring system, and the transitional arrangements with suspended guidelines from 2015. All of this leads into how we can assist clients in the applicable industries (and ourselves) to make key decisions that will determine whether they will be in the crosshairs of this targeting system for ATO compliance reviews.
Author profile
David Montani CTA
David Montani, CTA, is National Head of Technical Tax – Private Enterprise at Grant Thornton. He has over 30 years’ experience, with over 20 of those in specialist tax advisory. In his role with GT, David delivers practical tax training, mentors staff, provides tax technical support on significant client engagements, and assists with quality and excellence protocols. - Current at 13 November 2025
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