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In this edition of our Australian International Tax Update, we summarise recent significant Australian tax developments, examine their practical impact, and outline actions that multinational groups, foreign investors, private equity funds and international advisers should consider.

Loss carry back Australia 2026 helps companies turn tax losses into refunds and improve cash flow.

US retail expansion: sales tax nexus, compliance and key tax considerations for Australian retailers.

The ATO’s draft PCG 2026/D1 introduces a new compliance framework for attributing risk weighted assets to Australian branches of foreign banks, reshaping thin capitalisation methodologies and documentation expectations.

The Full Federal Court confirms that owner and beneficiary benefits in family businesses are not automatically subject to FBT, reinforcing the meaning of “in respect of employment” and providing guidance ahead of the 2026 FBT season.

From 1 April to 30 June 2026, Australia’s fuel excise is halved and the Road User Charge removed, impacting fuel tax credit (FTC) rates for businesses. Learn how these changes affect claims and compliance.

ATO expands reportable tax position (RTP) reporting to large CIVs and super funds – what it means and how to prepare.

OECD announces the ‘Side-by-Side’ administrative guidance package

On 10 November 2025, the Federal Court handed down its decision in Newmont Canada FN Holdings ULC v Commissioner of Taxation (No 2) [2025] FCA 1356.The case provides important guidance on the interpretation of ‘taxable Australian real property’ (TARP) under Division 855 of the Income Tax Assessment Act 1997 (Div 855).

The ATO has published its Public Country-by-Country (CbC) reporting implementation guide, effective for reporting periods starting on or after 1 July 2024.

Australia’s Country-by-Country (“CbC”) reporting regime has evolved significantly in recent years, reflecting a broader global shift towards tax transparency

ATO tax reviews 2025: ATO targeting privately owned and wealthy groups with Top 500, Next 5000 and Medium and Emerging Private Groups programs.