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The Australian Parliament recently passed legislation to introduce two significant tax incentives aimed at bolstering Australia’s critical minerals and hydrogen production sectors. The incentives form a significant part of the Government’s ’Future Made in Australia‘ policy.

The ATO raised concerns about franked dividends funded by capital raising, leading to Taxpayer Alert (TA 2015/2) and legislation. On December 4, 2024, the ATO issued draft PCG 2024/D4 to clarify its compliance approach.

Australia's Parliament has passed the Pillar Two rules, aligning with the OECD's global initiative to establish a 15% minimum tax rate for large multinational enterprises (MNEs).

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.

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

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.

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.

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.

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 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.

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.