Our latest insights

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

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.

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.

As of April 9, 2025, a minimum universal tariff of 10 per cent has been applied to all imported goods into the United States, while certain countries face higher reciprocal tariffs based on their US trade deficit.

Skills gaps in customs and trade threaten the bottom line and restrict future growth. While recruitment strategies are the key to solving this challenge in the long term, customs and trade managers can ensure operational tasks and strategic projects stay on track by bringing in a trusted, external partner to act as an extension of their team.

Organisations are bringing cost diligence back into the customs and trade planning equation in response to improving supply chain conditions. But finding cost efficiencies should not lead to higher risk, lower quality, slower delivery times, or detract from customer satisfaction. Instead, the focus should be on strategies that are a win for both the customer and your organisation’s bottom line.