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.
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In the 2024-25 Federal Budget, the Government announced the discontinuation of previously announced rules to deny, from 1July 2023, tax deductions for payments made by Significant Global Entity’s (SGEs) relating to intangible assets connected with low corporate tax jurisdictions.
Treasury has recently released for consultation two draft Bills, announced as part of the 2023-24 Budget, to implement incentives for new Build-to-rent (“BTR”) developments. This forms part of the Governments key policy of increasing housing supply across Australia by stimulating interest in the BTR sector.
On 21 March 2024, the Federal Treasury released a package of Exposure Draft bills and Explanatory Memoranda in respect of the OECD Pillar Two global/domestic alternative minimum tax rules.
There is never an ideal time for receiving an ATO review, and the time commitment (and possibly the costs) can be significant when a taxpayer is ill-prepared.
The long-anticipated tax legislation impacting off-market share buy-backs and selective share reductions passed the Senate on 16 November 2023 and is awaiting Royal Assent.
On 7 June 2023, the ATO released the finalised Taxation Ruling TR 2023/1 on residency tests for individuals.
On 22 June 2023, the Federal Government introduced the Treasury Laws Amendment (Making Multinationals Pay Their Fair Share – Integrity and Transparency) Bill 2023 into the House of Representatives. This Bill has been referred to the Senate Economics Legislation Committee with its Report due 31 August 2023.
Improvements are needed for Government changes to Thin Capitalisation regime’s Exposure Draft (ED) legislation which will apply mainly to multinationals with high interest deductions for income years commencing on or after 1 July 2023. Grant Thornton have identified a number of areas of interest in submissions to Government which reflect our analysis and include the views of our affected clients and their bankers and lawyers.
The Government has released anti-avoidance measures, which from 1 July 2023 will deny tax deductions to Australian Significant Global Entities (SGEs) in respect of payments for intangible assets to related party offshore group entities in low tax jurisdictions.
On 16 March 2023 the Federal Government released its Exposure Draft (ED) legislation, which was first announced as part of its October 2022 Federal Budget Thin Capitalisation measures.
On 16 March 2023 the Federal Government released its Exposure Draft (ED) legislation giving effect to its October 2022 Federal Budget thin capitalisation measures, which will apply mainly to multinationals with high interest deductions for income years commencing on or after 1 July 2023.