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US tariffs and IEEPA changes impacts on Australian exporters and trade compliance.
What Australia’s Carbon Leakage Review means for trade, imports and business costs
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.
From the introduction of Pillar Two to increased debt deduction limitations and public reporting obligations, the international tax landscape is shifting rapidly.
Unlock ATT accreditation to boost trade compliance, speed, and global market access.
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
US tariffs 2025: Impact on Australian exports, trade strategy & customs review insights.
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.
The ATO’s draft guidance PCG 2025/D4 tightens the rules on when cross-border software payments are treated as royalties and subject to withholding tax.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.
The ATO has released its draft guidance ‘PS LA 2025/D1 – Public country-by-country reporting exemptions’ outlining criteria and requirements for taxpayers applying for exemptions from public CbC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.
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.