Our latest insights

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.

The ATO has amended PCG 2018/9 to extend the corporate tax residency transitional period until 30 June 2023 to allow taxpayers to change their governance arrangements with respect to central management and control of foreign incorporated subsidiaries. The ATO has stated that the transitional period will not be extended again.

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.

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.

If you are an Australian professional services firm with clients who are residents in Singapore and are not registered for GST in Singapore, you must be aware of a potential requirement to register and pay GST in Singapore under its new Overseas Vendor Registration (OVR) regime.

Tariffs on emissions-intensive imports are expected to be introduced to adhere to the Government’s proposed emission targets. Climate Change and Energy Minister Chris Bowen put forward a proposal to enforce pollution caps on the country’s 215 biggest emitters, with the view to reduce their greenhouse output by 5 per cent a year until 2030. There’s no doubt that these emission targets are aggressive – but with penalties in place if organisations don’t comply, we expect to see a positive impact on the adoption of sustainable practices across businesses, manufacturing processes and along the supply chain.

With the Australia-India Economic Cooperation and Trade Agreement passing through Federal Parliament of Australia last week, now's the ideal time to assess your India strategy. What are the key opportunities your Agribusiness, Food & Beverage business can explore as part of your India strategy? Find out more about areas of opportunity you can leverage.

On 6 October 2022, the ATO released Draft Taxation Ruling TR 2022/D2 Income Tax: residency tests for individuals. TR 2022/D2 has consolidated and replaced previous ATO rulings, TR 98/17 and IT 2650 (both withdrawn effective 6 October 2022) on the ATO’s interpretation of the residency rules as set out in Section 6(1) of the Income Tax Assessment Act 1936.

The Federal Government’s Jobs and Skills Summit brought Government, employers, unions and the broader community together with the aim of building a bigger, better trained and more productive workforce, boosting real wages and living standards for Australians. But how will it affect businesses in the short term – and the long term?