PCG 2022/2.

Written by Claude Haiku 4.5 from the extracted text on 27 Feb 2026. It can miss or misread redacted and scanned pages. Check the source before relying on it.

PCG 2022/2 is a Practical Compliance Guideline establishing the ATO's administrative approach to Section 100A reimbursement agreements involving trust distributions. The guideline provides taxpayers with a compliance framework categorizing arrangements into white, green, and red zones based on risk profiles. Green-zone arrangements (low risk) include distributions to family members, direct beneficiary use of entitlements, trustee retention of funds, and ordinary family or commercial dealings, provided these follow the guideline in good faith. Red-zone arrangements (high risk) encompass situations where beneficiaries lend or gift entitlements, return trust income to the trust, issue units with set-off against entitlements, receive income shares significantly exceeding entitlements, involve loss-making beneficiaries outside family groups, or are subject to Taxpayer Alerts. The guideline specifies record-keeping requirements and applies to arrangements commencing on or after