Australia’s evolving tax landscape: from reform to compliance reality

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Quick summary
  • The Australian international tax landscape continues to evolve at pace, with 2026 representing the implementation of a number of initiatives – such as Pillar Two and Public CbC reporting – that impact multinationals.  
  • The 2026-27 Federal Budget introduced a pipeline of reforms that will continue to shape how international businesses operate in Australia, even where the impact is indirect.
  • The above changes, coupled with increased ATO compliance activity and evolving judicial interpretation, means Australian multinational groups and foreign investors investing in Australia face an increasingly complex regulatory environment.
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.
Australian international tax: June 2026
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Australian international tax: June 2026

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Among the developments covered in this publication are: 

  • Pillar Two moving from theory to practice – Australia’s global and domestic minimum tax rules are now in force, with first lodgement obligations live for in-scope multinational enterprise groups. Further amendments are also expected as Australia progresses implementation of the OECD/G20 side-by-side package.

  • Public CbC Reporting – Australia’s Public CbC reporting regime is now an established part of the tax transparency landscape. Key themes from the first round of lodgements include the importance of a robust approach to tax disclosures, clear explanations for differences between tax accrued and expected tax expense, and a theme of exemption requests from US private multinationals due to concerns over the disclosure of commercially sensitive information.

  • Foreign resident CGT reforms – proposed changes to Australia’s foreign resident capital gains tax regime continue to progress, including a broadened concept of Australian real property and changes that may expand the circumstances in which foreign investors are subject to Australian tax on disposals of interests in Australian entities. 

  • Loss carry back reintroduced – the Government is reintroducing a loss carry back regime for eligible companies, which may create cash-flow opportunities for corporate groups with Australian operations (subject to eligibility requirements and franking account limitations).

Turning tax strategy into an advantage

As Australia's international tax rules continue to evolve, businesses should proactively assess the implications for their structures, transactions and compliance obligations. Our team can help you navigate these changes with confidence and transform regulatory complexity into strategic advantage.

Learn more about how our International tax services can help you
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Learn more about how our International tax services can help you