Advice under development: Application of Part IVA to property development agreements involving long-term construction contracts – ATO compliance approach
Issue: Long-term construction contracts
Category: Income tax
Type of advice: Final Practical Compliance Guideline
Status: Under development
Expected completion: Mid to late 2026
Purpose: This Guideline will set out our proposed compliance approach to long-term construction contract arrangements (projects that span a period of greater than one year) in the property and construction industry. | This Guideline accompanies Taxpayer Alert TA 2026/1 Contrived property development arrangements between related parties that defer recognition of income and exploit tax losses .
Comments: Draft Practical Compliance Guideline PCG 2026/D2 Application of Part IVA to property development arrangements involving long-term construction contracts – ATO compliance approach published on 1 April 2026. Comments period closed 15 May 2026.
Referenced documents: TA 2026/1 | PCG 2026/D2