On 2 March 2021 the Australian Taxation Office (ATO) issued Rio Tinto Limited with amended assessments related to the denial of interest deductions on an isolated borrowing used to pay an intragroup dividend in 2015. The borrowing was repaid in 2018.
The ATO has today issued further assessments in relation to the same transaction levying penalties of A$352m (US$257.9m) and reducing the original interest assessment from A$47m to A$27m (US$19.8m).
Borrowing to fund the payment of a dividend is a normal commercial practice. Rio Tinto is confident of its position and will dispute the primary tax and penalty assessments. In accordance with the usual practice Rio Tinto has paid 50% of the primary tax up-front as part of the objections process. Penalties and interest are not required to be paid until the primary tax matter is resolved.
Rio Tinto Limited paid more than A$8.4bn (US$6.4bn) of Australian income tax during the relevant period.
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