Our latest insights

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.

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.

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.