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The ATO’s draft guideline PCG 2025/D2 outlines how taxpayers must determine an arm’s length debt amount for related-party loans under transfer pricing rules. It challenges the use of guarantees to inflate borrowing capacity and introduces a risk assessment framework to classify arrangements by compliance risk. Robust documentation is essential to support deductions.

This report explores the key tax considerations that arise throughout the lifecycle of a typical M&A transaction, from initial planning through to final stages of execution.

The Australian tax landscape for multinationals has significantly shifted with the implementation of the Debt Deduction Creation Rules (DDCR) (in Subdivision 820-EAA of the ITAA 1997).

On Thursday 5 June South Australian Treasurer Stephen Mullighan delivered the state budget, focusing on housing, crime and cost of living. This budget forecasted a surplus of $18m for 2024-25, with the government estimating surpluses for the next four years. The net operating surplus is estimated to be $315m by 2028-29.

Tasmanian Treasurer Guy Barnett delivered his first state budget on Thursday 29 May alongside Premier Jeremy Rockliff.

On Tuesday 20 May 2025 Victoria’s first female Treasurer, Jaclyn Symes, delivered her inaugural budget alongside Premier Jacinta Allan. For the first time in five years, the state reported an operating surplus at $600m, with projected surpluses of $1.9b in 2026–27, $2.4b in 2027–28, and $1.5b in 2028–29. Net debt is $167.6b, with it forecasted to increase to $194b by 2028-29.

Alongside Chief Minister Lia Finocchiaro, Treasurer Bill Yan focused on reducing crime and increasing public service employee costs in supporting hospital and correction services.

For wine producers and vineyard owners, the recent New South Wales Civil and Administrative Tribunal decision in Zonadi Holdings Pty Ltd ATF Wombat Investment Trust v Chief Commissioner of State Revenue [2025] NSWCATAD 84 may spell trouble for their current primary production land tax exemptions.

ADIs are navigating regulatory reform, digital transformation, and rising fraud risks by strengthening governance, modernising infrastructure, and aligning strategy with compliance to drive resilience and long-term value.

As the regulatory landscape continues to evolve, it's crucial for small businesses in Australia to stay updated on new compliance requirements. One significant area is sustainability reporting due to the Australian government's introduction of mandatory sustainability reporting requirements. While these regulations may not directly apply to small businesses, understanding their implications is essential for maintaining strong commercial relationships and ensuring future compliance.

M&A deal volumes are down, but industry deal composition suggests Australia’s M&A landscape has largely stabilised. IMs led the charge by deploying long-held capital, while IPOs are subdued – likely into the future. Industrials continues to be the sector driving activity, and SMEs again remain some of the most sought-after targets for acquisition.

In this episode, Corporate Tax Partner Vince Tropiano, Global Trade Partner Richard Nutt and Innovation Incentives Director Simone Barker discuss the Australian economy and how tariffs are impacting Australian manufacturing businesses – and what they can do to mitigate risks.