Part IVA - General Anti-Avoidance
PCG 2021/4 [3]
Profit Allocation in Professional Services Firms
6 June 2025
PCG 2021/4 is more than just guidance—it’s changing how accountants advise clients and how firms structure their businesses. In this 3rd and last video in the series on PCG 2021/4, we unpack the assumptions behind the PCG, challenge its logic, and explain why it may be time for the ATO to step back.
30 minutes.
PCG 2021/4 [2]
Profit Allocation in Professional Services Firms
30 May 2025
This video is the second in a three-part series on PCG 2021/4 and focuses on practical examples showing how the ATO applies the guideline in real-world situations. It walks through several detailed case studies involving individual professional practitioners (IPPs) to demonstrate how different income allocations, tax outcomes, and structures affect risk scores under the PCG’s framework. The video is particularly valuable for accountants advising clients on staying within the low-risk “green zone” and highlights how even small changes in income levels or distributions can shift a client into higher-risk categories.
29 minutes.
PCG 2021/4 [1]
Profit Allocation in Professional Services Firms
15 May 2025
PCG 2021/4 sets out the ATO’s compliance approach to how profits from professional firms are allocated to individual practitioners. It introduces a two-gateway test—commercial rationale and absence of high-risk features—and a risk assessment framework that categorises arrangements as green (low risk), amber (moderate risk), or red (high risk). While not legally binding, the guideline signals the ATO’s preferred position and implies the potential application of Part IVA where arrangements fall outside its green zone.
34 minutes.