On 9 August 2024, the ATO sought to appeal a decision exempting PepsiCo from RWHT, highlighting its focus on taxing embedded royalties, IP, and applying DPT.
Following the recent removal of tariffs on Australian wine by China, the industry is keen to rebuild relations and explore the right export markets. This presents Australian wine producers with a chance to reassess their position in the global market.
In 2015, the Australian government introduced the concept of a Significant Global Entity (SGE). Even if an Australian company has relatively small operations in Australia, it may still be considered an SGE if it part of a group with large turnover. Watch now as Vince Tropiano and Jessica Brass discuss the key issues to be aware of in respect to SGEs.
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.
STAI, a SingTel subsidiary, lost its court appeal, highlighting ATO’s focus on tax avoidance. STAI owes ATO $268m in tax and $125m in penalties due to debt deductions. The court found STAI paid excessive interest, benefiting SingTel.
PepsiCo appealed a court decision that found it owed the ATO AUD 3.6m in royalty withholding tax for FY 2018 and 2019.
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.
In this episode of Navigating the New Normal, Employment Solutions Partner George Bendall and Director Shivani Krishnamoorthy discuss the connection between ESG and global mobility programs.
Australia's commitment to reducing carbon emissions is taking a powerful step forward with the proposed green tariff. New regulation has been proposed by Australia's Climate Change Minister, Chris Bowen, through the implementation of a carbon border adjustment mechanism on steel and cement imports. Designed to ensure a level playing field for our domestic manufacturers, this initiative could reshape the business landscape by increasing costs on imports and emphasising environmental compliance.
On 7 June 2023, the ATO released the finalised Taxation Ruling TR 2023/1 on residency tests for individuals.
As part of the recently introduced Treasury Laws Amendment (Making Multinationals Pay Their Fair Share – Integrity and Transparency) Bill 2023 in Australian Parliament, the Federal Government has released an Exposure Draft dealing with Multinational tax transparency.