The ATO has released final guidance on the royalty characterisation of software distribution, intermediation and intellectual property arrangements through TR 2026/2 and draft PCG 2026/D4. The guidance clarifies when software-related payments may be treated as royalties and subject to royalty withholding tax, while introducing a practical compliance risk framework.
Filter insights by:
Showing 6 of 6 content results
OECD announces the ‘Side-by-Side’ administrative guidance package
The Australian Pillar Two Rules align with the OECD’s initiative to ensure MNEs pay a minimum Effective Tax Rate (ETR) of 15 per cent globally.
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).
Discover the ATO's new compliance initiative targeting medium-sized and emerging businesses. Learn about the key areas of focus, including trusts, Division 7A, CGT concessions, and income reporting, to ensure your business meets its tax obligations and avoids common errors.
Treasury is taking steps to ensure fairer tax treatment for foreign resident investors by tightening Australia's foreign resident Capital Gains Tax (CGT) regime. Proposed changes aim to broaden the CGT base and enhance integrity, impacting infrastructure, energy, agriculture, and more.