Australian Taxation Office issues Taxpayer Alert on treaty shopping arrangements to obtain reduced withholding tax rates

The Taxpayer Alert provides examples of treaty shopping arrangements that the ATO views as higher-risk arrangements which will warrant increased scrutiny by the ATO.

The TA is intended to enable informed decisions by taxpayers, prevent further spread of higher risk arrangements and to demonstrate risk detection ability.

The ATO recommends that in light of TA 2022/2, taxpayers should review their arrangements to identify transactions which may produce similar treaty benefits (i.e., reduced WHT) und…