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

Newsletter

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).

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