Our latest insights

The ATO has increased local file reporting requirements to better understand international tax risks. These changes apply from 1 January 2025, for periods starting on or after 1 January 2024. CbCREs will need more time and resources to comply.

Australia's new Public Country-by-Country reporting law, effective 1 July 2024, mandates multinationals to disclose financial activities, tax practices, and profit allocation per country.

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.

The ATO has finalised PCG 2024/1, a framework to assess risk of ATO applying anti-avoidance or transfer pricing rules to intangible assets.

STAI, a SingTel subsidiary, lost its court appeal, highlighting ATO’s focus on tax avoidance. STAI owes ATO $268m in tax and $125m in penalties due to debt deductions. The court found STAI paid excessive interest, benefiting SingTel.

The ATO has been undertaking assurance reviews as part of its Tax Avoidance Taskforce since 2016. These reviews are designed to provide assurance to the Government and the business community that taxpayers are meeting their tax obligations.

As part of the recently introduced Treasury Laws Amendment (Making Multinationals Pay Their Fair Share – Integrity and Transparency) Bill 2023 in Australian Parliament, the Federal Government has released an Exposure Draft dealing with Multinational tax transparency.

The ATO has released the revised Draft Practical Compliance Guideline PCG 2023/D2, outlining the compliance approach to intangibles arrangements involving international related parties, addressing the tax issues associated with restructures (“migration”) or mischaracterisation of Australian activities in connection with intangible assets.