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27 Jul 20221 min read
‘Treaty shopping’ broadly involves corporate groups interposing related entities in DTA friendly jurisdictions to obtain a more favourable WHT rate than would have applied if a payment from Australia were received directly by the ultimate recipient, in a country with no or a less favourable DTA with Australia.
The ATO will engage with taxpayers and advisers to scrutinise existing and proposed arrangements exhibiting features outlined in TA 2022/2, and in appropriate circumstances penalise the taxpayer under Australian tax laws, including using the “Part IVA” general anti-avoidance rules and/or diverted profits tax rules.
If you have entered into, or are contemplating entering into, an arrangement of this type, we encourage you to discuss your situation with your Grant Thornton contact.
The NSW Budget 2026 focuses on health and education spending, with slower growth forecasts, rising debt and targeted foreign investor duty relief measures.
On Tuesday 23 June 2026, Treasurer David Janetzki handed down his second state budget alongside Premier David Crisafulli. Deficits are forecast throughout the forward estimates, with a surplus of $619m projected for 2029-30.
The Government has announced revisions to several tax measures in the Budget, affecting capital gains tax treatment for small businesses, a special carve-out for start-ups, and a conditional exclusion for discretionary testamentary trusts from the 30 per cent tax on trusts.
