Advice under development: Low-risk payments relating to software arrangements – ATO compliance approach
Issue: Royalty withholding tax and software arrangements
Category: International
Type of advice: Final Practical Compliance Guideline
Status: Under development
Expected completion: To be advised
Purpose: Draft Practical Compliance Guideline PCG 2025/D4 Low-risk payments relating to software – ATO compliance approach provides practical guidance relating to our view set out in Draft Taxation Ruling TR 2024/D1 Income tax: royalties – character of payments in respect of software and intellectual property rights . | The final Guideline will provide guidance about when we consider there is a low risk that cross-border payments in connection with software arrangements have been mischaracterised and we will not apply compliance resources.
Comments: PCG 2025/D4 published on 6 August 2025. Comments period closed on 17 September 2025. All submissions are currently being considered.
Referenced documents: PCG 2025/D4 | TR 2024/D1