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Tax issues impacting foreign private equity in Australia
Insight Tax issues impacting foreign private equity in Australia
The ATO oversees tax structures for foreign PE investments in Australia. If FIRB approval is required, ATO and FIRB will review the structure. Due to strict anti-avoidance laws, investors should seek early tax advice to comply.
Avinesh Naidu
Cliff Chang
| 14 min read | 27 Sep 2024
ATO finalises Practical Compliance Guideline on Migration of Intangibles
Client Alert ATO finalises Practical Compliance Guideline on Migration of Intangibles
The ATO has finalised PCG 2024/1, a framework to assess risk of ATO applying anti-avoidance or transfer pricing rules to intangible assets.
Jason Casas
Christine Cornish
Keith To
| 6 min read | 31 May 2024
Denial of tax deductions: cross border payments for intangibles – discontinuation of measure
Client Alert Denial of tax deductions: cross border payments for intangibles – discontinuation of measure
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.
Brett Curtis
Yan Wong
| 2 min read | 21 May 2024
Updated ATO Draft Taxation Ruling – Payments for Software and Intellectual Property (IP)
Client Alert Updated ATO Draft Taxation Ruling – Payments for Software and Intellectual Property (IP)
Explore the impact of the latest ATO Draft Taxation Ruling on software and IP payments. Learn how overseas providers and taxpayers may be affected by changes in the ‘royalty’ definition, transfer pricing, and withholding tax rates. Understand the Commissioner's perspectives on royalties, copyright definitions, and tax treaty applications. For personalised guidance on adapting to these changes, connect with the Grant Thornton tax team.
7 min read | 30 Jan 2024
Changes to FIFO travel expenses
Insight Changes to FIFO travel expenses
The recent Court decision in the Bechtel Australia Pty Ltd v FC of T 2023 (the Bechtel case) ruling that fly-in-fly-out (FIFO) employees’ travel is deductible, has created a shift in the treatment of travel expenses for workers in mining, gas, transport and other industries. This ruling contrasts with the John Holland Group Pty Ltd v Commissioner of Taxation [2015] FCAFC82 (the John Holland case), causing notable effects.
Elizabeth Lucas
Elizabeth Lucas
| 5 min read | 23 Aug 2023
Improvements needed for Government changes to Thin Capitalisation regime
Client Alert Improvements needed for Government changes to Thin Capitalisation regime
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.
Michael Catterall
Yan Wong
Daniel Kave
Avinesh Naidu
Brett Curtis
| 2 min read | 17 Apr 2023
Denial of tax deductions: cross border payments for intangibles
Client alert Denial of tax deductions: cross border payments for intangibles
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.
Brett Curtis
Yan Wong
| 3 min read | 06 Apr 2023
Draft Thin capitalisation rules released to target multinational interest deductions
Client alert Draft Thin capitalisation rules released to target multinational interest deductions
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.
Michael Catterall
Yan Wong
Daniel Kave
Avinesh Naidu
Brett Curtis
| 3 min read | 17 Mar 2023
Assessing intangibles for compliance and R&D grant eligibility
Insight Assessing intangibles for compliance and R&D grant eligibility
In an increasingly digitised global world, technology is omni-present, transcends geographic boundaries, and influences every aspect of 21st century life. With this rapid change, invisible assets, or intangible assets (“intangibles”) are progressively more important value drivers for many Multinational Enterprises (MNEs). These intangibles have become the focus of tax controversy worldwide.
Jason Casas
Christine Cornish
Sukvinder Heyer
Uma Adash
| 9 min read | 15 Mar 2023
Global minimum 15 per cent corporate tax rate – Australia moves closer to implementation
Client alert Global minimum 15 per cent corporate tax rate – Australia moves closer to implementation
The imposition of a 15 per cent global minimum tax for multinational corporate groups appears imminent but there is still a lot of work to do to finalise details. Here’s what we know so far and how it may impact multinational businesses including pillar 2, GloBe and Safe harbour considerations.
Brett Curtis
Brett Curtis
| 7 min read | 09 Mar 2023
Off market share buyback and capital raisings franking legislation introduced
Client Alert Off market share buyback and capital raisings franking legislation introduced
After a long period of consultation, the Federal Government introduced the Treasury Laws Amendment (2023 Measures No.1) Bill 2023 into parliament on Thursday 16 February 2023.
Yan Wong
Tim Hands
Vince Tropiano
| 4 min read | 17 Feb 2023
ATO targets “Everett Assignments” by professionals
Client alert ATO targets “Everett Assignments” by professionals
Following on from the ATO’s guide to professional services firms’ allocation of profits in PCG 2021/4, the ATO has now further tightened its compliance scrutiny of individual professionals’ ability to assign or stream income away from themselves to family members by releasing its compliance approach to so-called Everett assignments.
Yan Wong
Ben Matthews
| 2 min read | 06 Jul 2022
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