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PepsiCo appeals landmark decision
Client Alert PepsiCo appeals landmark decision
PepsiCo appealed a court decision that found it owed the ATO AUD 3.6m in royalty withholding tax for FY 2018 and 2019.
Michael Catterall
Jason Casas
Aliece Graham
Christine Cornish
| 7 min read | 08 Feb 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
Major changes to Australia’s Thin Capitalisation rules are expected to be enacted soon
Client Alert Major changes to Australia’s Thin Capitalisation rules are expected to be enacted soon
Australia is set to introduce new Thin Capitalisation rules, which may limit a taxpayer’s debt deductions even more than under the current rules.
Michael Catterall
Michael Catterall
| 5 min read | 20 Oct 2023
Amended Multinational tax transparency reporting rules introduced into Parliament
Client alert Amended Multinational tax transparency reporting rules introduced into Parliament
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.
Jason Casas
Christine Cornish
Keith To
| 4 min read | 27 Jun 2023
ATO releases revised Practical Compliance Guideline on intangibles arrangements
Client Alert ATO releases revised Practical Compliance Guideline on intangibles arrangements
The ATO has released the revised Draft Practical Compliance Guideline PCG 2023/D2, outlining the compliance approach to intangibles arrangements involving international related parties, addressing the tax issues associated with restructures (“migration”) or mischaracterisation of Australian activities in connection with intangible assets.
Christine Cornish
Jason Casas
Keith To
| 4 min read | 23 May 2023
Will the Federal Budget reveal the Government’s long-term plan for supply chains?
Insight Will the Federal Budget reveal the Government’s long-term plan for supply chains?
With less than one week to go until Labor hands down its first Federal Budget, it will be interesting to see what the Government will do to help set up the future of Australia. Our economy – like many others around the world – is still experiencing supply chain pressures, and with a potential global recession looming, there are some steps the Government could take to ensure Australia’s economic strength over the long term.
Richard Nutt
Richard Nutt
| 4 min read | 20 Oct 2022
Investment into innovation encouraging stability in manufacturing
Insight Investment into innovation encouraging stability in manufacturing
Australian manufacturers have been through difficult times, particularly with the shutdown of the automotive industry, but remaining businesses are proving to be agile and resilient having already battled through lots of challenges. In addition, the accelerating pace of new technologies being introduced, combined with COVID-19 disruption and the Government’s substantial industry support, many manufacturing business models have been fundamentally challenged for the better.
Michael Climpson
Nick Love
Matt Byrnes
| 4 min read | 13 May 2022
Tax considerations for Fintechs
Insight Tax considerations for Fintechs
The ATO has recently undertaken a number of Income tax, Transfer Pricing, GST and R&D reviews of Fintechs across the ‘Top 1000’ and the ‘Medium and Emerging’ markets, focusing on business models such as online lenders, neo banks, buy now pay later providers, and peer-to-peer lenders. Based on the findings, the ATO has identified a number of key risk areas.
Himashini Weeraratne
Matthew Leivesley
| 9 min read | 02 Dec 2021
Supply chain disruptions and transfer pricing trends
Insight Supply chain disruptions and transfer pricing trends
Supply chain pressures are not unique to multinational enterprises (MNEs). But when combined with trade protectionism measures, evolving international tax policies, and technological disruption, the current global pandemic has created the perfect storm. The COVID-19 crisis has had an unprecedented impact on international supply chains – from delays in production and logistics, through to loss of confidence in global networks, supply chains have been well and truly tested.
Jason Casas
Richard Nutt
| 6 min read | 19 Nov 2021
Is it time to review your transfer pricing and group structure?
Insight Is it time to review your transfer pricing and group structure?
Due to COVID-19 many businesses are considering what broader changes are needed to their corporate structures.
21 May 2020
Important changes to the Arm’s Length Debt Test
Client Alert Important changes to the Arm’s Length Debt Test
On 5 April 2019, the ATO released Draft Taxation Ruling, TR 2019/D2 to clarify how entities should utilise the ALDT (“the ALDT Draft Ruling”). This ruling applies retrospectively.
Jason Casas
Jason Casas
| 3 min read | 14 May 2019
Multinational anti-avoidance legislation
Client Alert Multinational anti-avoidance legislation
The Tax Law Amendment (Combating multinational Tax Avoidance) Bill 2015 (“MAAL”) casts the spotlight onto corporate activity that encourages the reduction of tax liabilities in Australia.
Brett Curtis
Vince Tropiano
Jason Casas
| 3 min read | 21 Jun 2017
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