This webinar is designed for professionals responsible for managing, advising on or overseeing cross-border intangibles and software arrangements within multinational operations in Australia.

• CFOs and Tax Managers of Australian-based multinationals with cross-border related party dealings involving IP or software
• In-house tax and finance teams responsible for transfer pricing compliance and documentation
• Accountants and tax advisors managing clients with intangibles migration arrangements or cross-border software payments
• MNE decision-makers in industries with significant IP, SaaS, fintech, or technology-driven operations looking to proactively manage ATO risk

By the end of the webinar, attendees will be able to:

• Understand the ATO's risk framework for intangibles - Learn how PCG 2024/1 categorises intangibles migration arrangements across green, blue, amber, red and white risk zones and what each rating means for your compliance exposure.
• Navigate the safe harbour criteria for software payments - Know exactly when cross-border software payments fall within the white or green zone under PCG 2025/D4 and when they may attract ATO scrutiny as potential royalties.
• Build a defensible compliance position - Gain practical strategies for documenting, benchmarking and structuring intangibles arrangements to reduce audit risk and protect your transfer pricing positions.

Setting the Scene: Why Intangibles Are the ATO's Top Priority

• The ATO's escalating focus on cross-border IP, intangibles migration and software payment classification
• The link between PCG 2024/1, PCG 2025/D4 and draft Taxation Ruling TR 2024/D1
• Why PCGs matter: they signal how the ATO assesses behaviour, conducts reviews and prioritises audit activity.

2. PCG 2024/1 Deep Dive: Intangibles Migration Arrangements

• Scope and key definitions - intangible assets, migration, DEMPE functions (Development, Enhancement, Maintenance, Protection, Exploitation)
• The two risk assessment categories: migration of intangible assets vs. mischaracterisation/non-recognition of Australian activities
• Colour-coded risk zones (green, blue, amber, red, white) and the ATO's scoring system
• Evidence expectations: the type and level of documentation the ATO requires to support your self-assessment.

3. PCG 2025/D4 Deep Dive: Low-Risk Software Payments

• Purpose, scope and the connection to the PepsiCo High Court decision
• White zone (pre-assured arrangements): APAs, court decisions, prior ATO review
• Green zone (safe harbour arrangements): the four illustrative examples - private-use software, cloud-based business tools, physical software resale, and embedded software in tangible goods
• What falls outside the safe harbours and what that means for withholding tax obligations.

  4. Proactive Strategies: Protecting Your Position   

• Structuring intangibles arrangements to align with low-risk frameworks
• When to consider Advance Pricing Arrangements (APAs) or proactive ATO engagement
• How PCG compliance connects to your broader transfer pricing documentation - Local File, Master File and IDS
• Key dates, consultation windows and next steps to stay ahead of finalisation.

5. Q&A Session

• Open floor for questions
• Live, practical guidance on specific scenarios raised by attendees.

The ATO has made it clear: intangibles are in its crosshairs. With PCG 2024/1 now in force and PCG 2025/D4 shaping the compliance landscape for software payments, the risk of getting it wrong - whether through an unexpected royalty withholding obligation, a mischaracterised DEMPE arrangement or a red-zone self-assessment - has never been higher. This webinar gives you the clarity and practical frameworks to act now rather than react later. Led by TPS directors with deep, hands-on experience advising multinationals across Australia and Asia, you'll leave with a clear understanding of what the ATO expects to see and exactly what steps to take to strengthen your position.