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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.

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.

PepsiCo embedded royalties, ATO Decision Impact Statement, embedded royalties Australia, royalty withholding tax, diverted profits tax, intellectual property payments, IP arrangements Australia, multinational tax Australia, ATO royalties guidance

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.