WEBINAR: Transfer Pricing with Intangibles in Australia

Events • WEBINAR: Transfer Pricing with Intangibles in Australia

WEBINAR
Transfer Pricing with Intangibles in Australia


Thursday 16 July, 2026	2:00 - 3:00p.m.	LIVE Webinar

Intangibles Under the ATO's Lens:
What PCG 2024/1 and PCG 2025/D4 Mean for Your Business.

The ATO has significantly escalated its focus on cross-border intangibles arrangements, making this one of the most consequential compliance areas for multinationals operating in Australia. With the finalisation of PCG 2024/1 in January 2024 and the release of draft PCG 2025/D4 in August 2025, the ATO has established a detailed risk framework targeting intangibles migration, mischaracterisation of Australian DEMPE activities, and the royalty classification of cross-border software payments.

This webinar brings together both PCGs into one practical session, giving attendees a clear understanding of how the ATO assesses risk across intangibles arrangements - from IP migration and profit allocation through to everyday software licensing. We'll break down the colour-coded risk zones, the self-assessment process, the ATO's evidence expectations, and the safe harbour criteria under PCG 2025/D4, including the white and green zone examples that define what the ATO considers low risk.

Led by Shannon Smit and Hong Chuan Tan of Transfer Pricing Solutions Australia, this session is designed to cut through the complexity and give you the practical tools to assess, document and defend your intangibles arrangements with confidence.

Who Should Attend?

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

Learning Objectives / Overview

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.

Agenda ~ 60 Minutes

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.

Why You Should Attend

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.

Meet the Speakers

Regional Transfer Pricing Specialists with deep experience in tariff-affected TP planning for MNE supply chains and proven track record in intercompany contract design, APA negotiation & TP risk management.

Shannon Smit

Founding Director

BIO

Shannon Smit is the founding director of Transfer Pricing Solutions and has consulted multi-national companies on transfer pricing, taxation and accounting for over 25 years. Transfer Pricing Solutions has been recognized for their expertise, and in 2017 Shannon was thrilled to be awarded Asia Pacific Transfer Pricing Leader of the Year.

Shannon’s career has provided her with a wide range of experience including global project management, transfer pricing and operational implementation for large-scale business transformation projects. She also has hands-on implementation experience with supply chain issues and managing interrelationships between international tax, accounting, IT systems and training of operations personnel. With eight years spent working in the USA and Europe, she has extensive experience in advising both Australian and foreign multi-national companies. Their clients include large ASX listed companies, private Australian companies, SME clients, foreign subsidiaries based in Australia, accounting and law firms.

Shannon was appointed to the Australian Governments Board of Taxation’s Working Group as an Expert Panel Member for the Review of Tax Impediments Facing Small Business and Shannon also lectures in Transfer Pricing as a part of the Melbourne University’s Law School International Tax Program.

Hong Chuan Tan

Partner (AU)

BIO

Hong Chuan has comprehensive experience in transfer pricing where he has assisted clients with transfer pricing planning and risk management, transfer pricing documentation, Country-by-Country Reporting, and tax effective supply chain management in the Asia Pacific region, Australia, the US and the UK. His passion lies in optimising tax efficiency while ensuring compliance with the prevailing transfer pricing regulations. He also actively participated in transfer pricing reviews and audits with the Australian Taxation Office and Malaysian Inland Revenue board.

Hong Chuan takes pleasure in knowledge sharing and is a regular speaker in transfer pricing webinars/ seminars and workshops.

Transfer Pricing with Intangibles in Australia

Understand where your intangibles arrangements sit on the ATO's risk radar.

WEBINAR: Transfer Pricing with Intangibles in Australia