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From the introduction of Pillar Two to increased debt deduction limitations and public reporting obligations, the international tax landscape is shifting rapidly.

OECD announces the ‘Side-by-Side’ administrative guidance package

On 10 November 2025, the Federal Court handed down its decision in Newmont Canada FN Holdings ULC v Commissioner of Taxation (No 2) [2025] FCA 1356.The case provides important guidance on the interpretation of ‘taxable Australian real property’ (TARP) under Division 855 of the Income Tax Assessment Act 1997 (Div 855).

Unlock ATT accreditation to boost trade compliance, speed, and global market access.

The ATO has published its Public Country-by-Country (CbC) reporting implementation guide, effective for reporting periods starting on or after 1 July 2024.

US tariffs 2025: Impact on Australian exports, trade strategy & customs review insights.

The High Court of Australia has dismissed the Tax Commissioner’s (“the Commissioner”) appeals in FCT v PepsiCo, Inc [2025] HCA 30 (“PepsiCo”), ruling that payments made by Schweppes Australia to PepsiCo’s Australian subsidiary for concentrate did not constitute royalties, and that PepsiCo and Stokely‑Van Camp were not liable for royalty withholding tax or diverted profits tax for the 2018 and 2019 income years.

Like many countries, Australia taxes its residents on the income and capital gains they generate irrespective of where they are sourced. For ‘temporary residents’, understanding how the rules operate in detail – and even your relationship status – is necessary to determine your tax position.

While the Division 296 tax is still yet to be legislated, it’s looking likely the tax will be introduced. For individuals who may be impacted by the change, it’s critical to understand how different scenarios might play out and what they should consider.

The ATO’s draft guideline PCG 2025/D2 outlines how taxpayers must determine an arm’s length debt amount for related-party loans under transfer pricing rules. It challenges the use of guarantees to inflate borrowing capacity and introduces a risk assessment framework to classify arrangements by compliance risk. Robust documentation is essential to support deductions.

The Australian tax landscape for multinationals has significantly shifted with the implementation of the Debt Deduction Creation Rules (DDCR) (in Subdivision 820-EAA of the ITAA 1997).

In this episode, Corporate Tax Partner Vince Tropiano, Global Trade Partner Richard Nutt and Innovation Incentives Director Simone Barker discuss the Australian economy and how tariffs are impacting Australian manufacturing businesses – and what they can do to mitigate risks.