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ATO PCG 2019/1: updated transfer pricing risk assessment for inbound distributors
Client Alert ATO PCG 2019/1: updated transfer pricing risk assessment for inbound distributors
The ATO has released a draft update to PCG 2019/1, proposing several important refinements to the transfer pricing risk assessment framework for inbound distribution arrangements. The guidance is relevant for businesses operating as inbound distributors.
Keith To
Jason Casas
Christine Cornish
Rashtin Fazal
| 6 min read | 04 Feb 2026
ATO finalises guidance on Country-by-Country reporting exemptions: Key considerations for multinationals
Client Alert ATO finalises guidance on Country-by-Country reporting exemptions: Key considerations for multinationals
Following on from our previous alert, the Australian Taxation Office (ATO) has finalised Practice Statement PS LA 2025/2, which sets out their administrative approach to the Commissioner’s discretion for granting an exemption from Public Country-by-Country reporting obligations. These rules require certain multinational groups to publicly disclose tax and financial information.
Keith To
Jason Casas
Christine Cornish
Rashtin Fazal
| 4 min read | 11 Dec 2025
ATO’s implementation of Public Country-by-Country reporting: what multinationals need to know
Client Alert ATO’s implementation of Public Country-by-Country reporting: what multinationals need to know
The ATO has published its Public Country-by-Country (CbC) reporting implementation guide, effective for reporting periods starting on or after 1 July 2024.
Keith To
Jason Casas
Christine Cornish
Rashtin Fazal
| 6 min read | 27 Oct 2025
From compliance to transparency: key developments in Australia’s Country-by-Country Reporting Regime
Insight From compliance to transparency: key developments in Australia’s Country-by-Country Reporting Regime
Australia’s Country-by-Country (“CbC”) reporting regime has evolved significantly in recent years, reflecting a broader global shift towards tax transparency
Rashtin Fazal
Jason Casas
Christine Cornish
Keith To
| 5 min read | 07 Oct 2025
PepsiCo — High Court dismisses Commissioner's appeals on embedded royalties and Diverted Profits Tax
Client Alert PepsiCo — High Court dismisses Commissioner's appeals on embedded royalties and Diverted Profits Tax
The High Court of Australia has dismissed the Tax Commissioner’s (“the Commissioner”) appeals in FCT v PepsiCo, Inc [2025] HCA 30 (“PepsiCo”), ruling that payments made by Schweppes Australia to PepsiCo’s Australian subsidiary for concentrate did not constitute royalties, and that PepsiCo and Stokely‑Van Camp were not liable for royalty withholding tax or diverted profits tax for the 2018 and 2019 income years.
Jason Casas
Christine Cornish
Keith To
Rashtin Fazal
| 5 min read | 19 Aug 2025
ATO releases draft guidance on cross-border software payments
Client Alert ATO releases draft guidance on cross-border software payments
The ATO’s draft guidance PCG 2025/D4 tightens the rules on when cross-border software payments are treated as royalties and subject to withholding tax. Businesses paying offshore software providers will need to review their arrangements against the new risk framework to avoid increased scrutiny and compliance risks.
Jason Casas
Christine Cornish
Keith To
Rashtin Fazal
| 4 min read | 13 Aug 2025
Navigating transparency: ATO releases draft guidance for public country-by-country reporting exemptions
Client Alert Navigating transparency: ATO releases draft guidance for public country-by-country reporting exemptions
The ATO has released its draft guidance ‘PS LA 2025/D1 – Public country-by-country reporting exemptions’ outlining criteria and requirements for taxpayers applying for exemptions from public CbC reporting requirements.
Jason Casas
Christine Cornish
Keith To
Rashtin Fazal
| 5 min read | 09 Jul 2025
Borrowing capacity and guarantees: ATO’s take on arm’s length debt amount
Client Alert Borrowing capacity and guarantees: ATO’s take on arm’s length debt amount
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.
Jason Casas
Christine Cornish
Keith To
Rashtin Fazal
| 6 min read | 23 Jun 2025
Impact of retaliatory tariffs on Australian and New Zealand exporters
Insight Impact of retaliatory tariffs on Australian and New Zealand exporters
As of April 9, 2025, a minimum universal tariff of 10 per cent has been applied to all imported goods into the United States, while certain countries face higher reciprocal tariffs based on their US trade deficit.
Richard Nutt
Keith To
Rashtin Fazal
Alejandro Ces
| 6 min read | 17 Apr 2025
Trade and tariffs: what does it mean for Australian businesses?
Insight Trade and tariffs: what does it mean for Australian businesses?
With the United States of America electing President Donald Trump for a second term, many economists are considering how this will affect both global and local economies. Whether potential tariffs come to fruition, Australian businesses should take this opportunity to review their supply chain, transfer pricing policies and export strategies and prepare ahead of time to lessen any potential impacts to their business.
Richard Nutt
Rashtin Fazal
| 4 min read | 06 Dec 2024
Impact of pending USA de minimis reforms on Australian retailers
Client Alert Impact of pending USA de minimis reforms on Australian retailers
The USA is preparing reforms to its de minimis exemptions, a change that could significantly affect Australian retailers selling goods manufactured in China and exporting to the USA. With higher tariffs and stricter customs regulations on the horizon, businesses may face increased costs and compliance challenges, requiring a reassessment of supply chain strategies.
Richard Nutt
Rashtin Fazal
| 4 min read | 25 Sep 2024
PepsiCo Update: ATO applies to the High Court for special leave to appeal
Client Alert PepsiCo Update: ATO applies to the High Court for special leave to appeal
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.
Michael Catterall
Jason Casas
Aliece Graham
Christine Cornish
Keith To
Rashtin Fazal
| 12 min read | 30 Aug 2024