On 9 August 2024, the ATO sought to appeal a decision exempting PepsiCo from RWHT, highlighting its focus on taxing embedded royalties, IP, and applying DPT.

Treasury is taking steps to ensure fairer tax treatment for foreign resident investors by tightening Australia's foreign resident Capital Gains Tax (CGT) regime. Proposed changes aim to broaden the CGT base and enhance integrity, impacting infrastructure, energy, agriculture, and more.

For renewable energy companies, understanding the implications of the new thin capitalisation rules is crucial. These rules will apply for income years starting on or after July 1, 2023.