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Diverted profits tax and multinational anti-avoidance law – practical insights
Published on 01 Apr 23 by "THE TAX SPECIALIST" JOURNAL ARTICLE
As the first diverted profits tax (DPT) case hits our courts, a degree of “mystery” continues to surround this anti-avoidance rule and its sister rule, the multinational anti-avoidance law (MAAL). Both rules are key tools in the ATO’s anti-avoidance arsenal, yet uncertainty remains as to when the ATO will seek to apply the rules and how organisations can engage with the ATO to avoid disputes in this arena. This article examines circumstances where the ATO is considering the DPT and MAAL, and how organisations can prepare if the ATO advises that the rules are potentially in scope.