Webinar: Structuring profits ahead of 30 June 2026

Understand how PCG 2021/4 is reshaping professional firm structures and what you should be doing now.

As 30 June approaches, professional firms are facing increasing scrutiny around profit allocation and structuring, driven by the ATO’s Practical Compliance Guideline (PCG 2021/4).

This webinar brings together RSM experts Peter Revelas, Partner, Business Advisory and Liam Telford, Partner, Tax Technical, to unpack what the guideline means in practice, how risk is assessed, and the steps firms and partners should take now to manage compliance and avoid unintended consequences.

The ATO’s focus on professional firm structures is not new, but enforcement and scrutiny have intensified.

PCG 2021/4 introduces a structured risk assessment framework, requiring firms and individual practitioners to actively demonstrate compliance through documentation, commercial rationale and ongoing review.

With year-end fast approaching, this is not a ‘set and forget’ exercise. Structures must be reviewed annually and supported by clear evidence.

This has moved beyond tax to become a firm-wide risk.

The ATO expects both firms and individual practitioners to take responsibility for compliance.

If one structure is high-risk, it can trigger scrutiny across the entire firm.

That makes alignment, governance and consistency critical.

Common pitfalls

Many firms unintentionally fall into higher risk categories due to:

overly complex structures without clear commercial rationale
profit allocations that don’t reflect economic reality
retained earnings that distort effective tax outcomes
misalignment between distributions and underlying cash flow

These factors can shift a structure from low-risk to review-triggering territory.

What to do before 30 June

To manage risk and ensure compliance:

Individual professional practitioners (IPPs)	Firms
Assess whether PCG 2021/4 applies to your structure.	Assess how PCG 2021/4 applies across your firm and partner base.
Review your individual profit allocation and expected year-end position.	Review firm-wide profit allocation frameworks and ensure alignment across partners.
Document the commercial rationale for your structure.	Establish and enforce a consistent commercial rationale framework across all structures.
Undertake a personal risk score assessment (pre 30 June where possible).	Implement a firm-wide risk assessment approach and oversight process.
Engage an adviser to validate your individual position and approach.	Engage advisers and/or provide centralised guidance to partners to ensure consistency and compliance.
	Ensure consistency across the firm and monitor compliance across all Ips.

Early action is critical - decisions made before year-end directly impact your risk profile.

Future considerations for professionals

Proposed changes flagged in the 2026 Federal Budget may further impact trust structures, but until legislation is finalised, firms should continue to operate within the current PCG framework.