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.
PepsiCo appealed a court decision that found it owed the ATO AUD 3.6m in royalty withholding tax for FY 2018 and 2019.
Australia is set to introduce new Thin Capitalisation rules, which may limit a taxpayer’s debt deductions even more than under the current rules.
On 22 June 2023, the Federal Government introduced the Treasury Laws Amendment (Making Multinationals Pay Their Fair Share – Integrity and Transparency) Bill 2023 into the House of Representatives. This Bill has been referred to the Senate Economics Legislation Committee with its Report due 31 August 2023.
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.
On 16 March 2023 the Federal Government released its Exposure Draft (ED) legislation, which was first announced as part of its October 2022 Federal Budget Thin Capitalisation measures.
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 this podcast, Tax Partners Michael Catterall and Lorena Sosa discuss aspects Australian businesses should consider when exploring new international markets, including operations and logistics, strategy planning, customs and duties, and tax complexities.
Technology companies face one of the most complex and risk-laden operating environments in the business world. Additional complexity has arisen recently from the rapid expansion of e-commerce and cloud computing, with global economic policies and tax frameworks struggling to keep pace.