Our audit team undertakes the complete range of audits required of Australian accounting laws to help you to help you meet obligations or fulfil best practice procedures.
There continues to be a spotlight on trust and integrity within the professional services industry. From our perspective, these have always been critical considerations.
We help clients understand and address their employment tax obligations to ensure compliance and optimal tax positioning for their business and employees.
We provide independent oversight and review of your organisation's control environments to manage key risks, inform good decision-making and improve performance.
We enable our clients to achieve their strategic objectives, fulfil their purpose and live their values supported by effective and appropriate risk management.
The Federal Court’s $5.8M ACL decision signals a new era for privacy, cybersecurity, and governance in Australia. It reinforces that privacy and cyber obligations start Day 1 of any acquisition, governance failures will be scrutinised, and accountability cannot be outsourced. Boards must ensure robust oversight, deep cyber due diligence, and forensic incident response. With OAIC escalating regulatory enforcement, organisations face heightened legal, financial, and reputational risks.
Our forensics team identifies and obtains relevant information, investigates the financial issue at hand and provides a clear, concise, sustainable opinion as...
Our team advises at all stages of a litigation dispute, taking an independent view while gathering and reviewing evidence and contributing to expert reports.
Our M&A team works with clients to achieve a full or partial sale of their business, to ensure achievement of strategic ambitions and optimal outcomes for stakeholders.
Our operational deal services team helps to ensure the greatest possible outcome and value is gained through post merger integration or post acquisition integration.
Our ESG due diligence process evaluates a company's environmental, social, and governance factors during the pre-investment phase to determine the overall maturity of the entity, manage potential risks, and identify opportunities.
Explore strategies for scaling in Australia’s tech and SaaS sector in this report, covering capital raising, investor expectations, and long-term growth.
Our finance and funding team works to access sources of finance, present your case to potential funders and negotiate a long-term sustainable relationship.
We provide effective and strategic corporate finance services across all stages of investments and transactions so clients can better manage costs and maximise returns.
We work closely with clients and lenders to provide holistic debt advisory services so you can raise or manage existing debt to meet your strategic goals.
Our proven methodology identifies opportunities to improve your processes and optimise working capital, and we work with to implement changes and monitor their effectiveness.
Explore strategies for scaling in Australia’s tech and SaaS sector in this report, covering capital raising, investor expectations, and long-term growth.
Our insolvency teams takes a proactive approach so our clients have access to more business turnaround options and retain the most value for all stakeholders.
As this year’s series kicks off in late 2025, continuing through to June 2026, we will bring you virtual on-demand webinars featuring guest speakers, legal and industry experts, and Grant Thornton specialists sharing insights and expectations for the year ahead.
We help clients improve commercial performance, profitability and address challenges after internal or external triggers require a major business model shift.
We provide strategic director advisory services in times of business distress to help directors navigate issues and protect their company and themselves from liability.
We work closely with clients and lenders to provide holistic debt advisory services so you can raise or manage existing debt to meet your strategic goals.
The Full Federal Court has handed down its decision in AusNet Services Limited v Commissioner of Taxation. AusNet argued that its 2015 restructure did not qualify for rollover relief under Division 615, despite that it earlier said it did. This case serves as a reminder that once a tax election is made, it is very difficult to unwind. Careful planning and forecasting are critical.
We work with private businesses across Australia – and internationals looking to Australia for their investments and operations – on all accounting and...
Our outsourced CFO services provide a full suite of CFO, tax and finance services and advice to help clients manage risk, optimise operations and grow.
Having a considered and informed ESG response has never been more important for all organisations as we are seeing awareness of the elements of ESG continue to...
Following the introduction of mandatory sustainability reporting requirements in Australia, organisations will need to understand if they are required to report, the disclosure requirements, and if they have the skill set and available data to comply. We can guide organisations through the reporting process end-to-end, from climate-related risks and opportunities identification through to reporting support.
With the ESG and sustainability landscape continuing to evolve, we are focused on helping your business to understand how to shape your sustainability strategy. When designing a sustainability strategy, it’s important to take into consideration your sustainability-related risks and opportunities, relevant standards and frameworks such as the SBTi, and your broader business needs.
The sustainability reporting regulations which have come into force in Australia include assurance requirements which are being phased in over several years. Australia is also the first jurisdiction internationally to adopt the new assurance standard. Whether you are seeking voluntary assurance or meeting your compliance obligations, our sustainability assurance team combines technical expertise and industry insights to provide quality and efficiency in the assurance process.
As ESG and Sustainability-related considerations are becoming pivotal for Australian dealmakers, it is important for investors to feel confident in assessing transactions through an ESG lens. The due diligence process evaluates a company's material environmental, social, and governance topics during the pre-investment phase, flagging risks and identifying opportunities for added value.
The Federal Court’s $5.8M ACL decision signals a new era for privacy, cybersecurity, and governance in Australia. It reinforces that privacy and cyber obligations start Day 1 of any acquisition, governance failures will be scrutinised, and accountability cannot be outsourced. Boards must ensure robust oversight, deep cyber due diligence, and forensic incident response. With OAIC escalating regulatory enforcement, organisations face heightened legal, financial, and reputational risks.
Investment and business opportunities in Vietnam are expanding rapidly, driven by new markets, diverse industries, and Vietnam's growing role in export manufacturing, foreign investment, and strong domestic demand.
In this episode of Beyond the Numbers with Grant Thornton, Management Consulting Partner, Richard Bycroft, and Director, Primo Danieletto, discuss automation in supply chains, triggers for reviewing an organisation’s current model and the ROI businesses can see from implementation.
The Federal Court decision in Morton v Commissioner of Taxation [2025] FCA 336 (“the Morton case”) provides key guidance on the tax treatment of proceeds derived from land development arrangements. This is particularly relevant to landowners considering development partnerships with third-party developers.
The ATO’s GSTD 2025/1 clarifies the GST treatment of prepared meals following the Simplot case. Learn how the new four-step test and transitional compliance approach affect food suppliers.
For wine producers and vineyard owners, the recent New South Wales Civil and Administrative Tribunal decision in Zonadi Holdings Pty Ltd ATF Wombat Investment Trust v Chief Commissioner of State Revenue [2025] NSWCATAD 84 may spell trouble for their current primary production land tax exemptions.
From an active natural resources M&A market, a growing energy and renewable energy market, to new technologies and export and trade agreements – we have the...
Mining contractors are operating in an increasingly complex and competitive Australian mining sector. With shifting commodity markets, cost pressures, and evolving contract models, understanding contractor performance, financial strength, and growth opportunities is more important than ever.
The Full Federal Court has handed down its decision in AusNet Services Limited v Commissioner of Taxation. AusNet argued that its 2015 restructure did not qualify for rollover relief under Division 615, despite that it earlier said it did. This case serves as a reminder that once a tax election is made, it is very difficult to unwind. Careful planning and forecasting are critical.
Australia’s new thin capitalisation rules significantly impact businesses with foreign ownership or offshore operations. If your business has debt deductions (such as interest deductions and borrowing costs) of more than A$2m, tax deductions could be denied under the primary ‘earnings tests’ (particularly if your EBITDA is low or negative due to early-stage losses, especially common in sectors like infrastructure and technology).
To manage the above risk, the legislation offers an alternative test: the Third Party Debt Test (TPDT).
The Federal Court’s $5.8M ACL decision signals a new era for privacy, cybersecurity, and governance in Australia. It reinforces that privacy and cyber obligations start Day 1 of any acquisition, governance failures will be scrutinised, and accountability cannot be outsourced. Boards must ensure robust oversight, deep cyber due diligence, and forensic incident response. With OAIC escalating regulatory enforcement, organisations face heightened legal, financial, and reputational risks.
In June this year, APRA published its eight proposed changes to its governance prudential standards. We have summarised APRA’s updated/clarified position and provided guidance on some steps that boards should be doing to prepare for the revised standards.
The Aged Care Act 2024 has been in place for a month. Touted as a ‘once in a generation change’ to improve protections for consumers, it also seeks to stimulate investment in residential care services and improve care in the home with the new Support at Home Program.
The Federal Court’s $5.8M ACL decision signals a new era for privacy, cybersecurity, and governance in Australia. It reinforces that privacy and cyber obligations start Day 1 of any acquisition, governance failures will be scrutinised, and accountability cannot be outsourced. Boards must ensure robust oversight, deep cyber due diligence, and forensic incident response. With OAIC escalating regulatory enforcement, organisations face heightened legal, financial, and reputational risks.
The health and aged care industry in Australia is complex and there are a range of challenges and opportunities for the banking sector which can be explored in relation to its various sub-sectors.
In this episode of Beyond the Numbers with Grant Thornton, Management Consulting Partner, Richard Bycroft, and Director, Primo Danieletto, discuss automation in supply chains, triggers for reviewing an organisation’s current model and the ROI businesses can see from implementation.
Discover how Australian manufacturers are responding to slower growth, rising costs and tighter margins in our 2025 Manufacturing Benchmarks report, with insights on performance, reinvestment and capability-building.
Against a backdrop of rising cost-of-living pressures and economic uncertainty, Not for Profits (NFPs) are facing increasingly complex challenges to maintain financial sustainability. With public expectations rising, funding pathways under strain, and operational costs climbing, many organisations are being forced to reassess how they operate. While the pressures are real, this also creates an opportunity to rethink collaboration, strengthen governance and build long-term resilience.
Australian charities are feeling the pinch of rising costs and increased demand as over 3.3m people live in poverty. From streamlining operations to diversifying funding streams and using technology like AI, leaders are finding ways to meet rising demand and stay resilient in today’s cost-of-living crisis.
Yalari is a not-for-profit organisation offering secondary education scholarships to Australian schools for First Nations students. The organisation champions the value of education and nurtures an encouraging community for students to thrive in their studies.
The ATO has made it clear that the professional services industry is in the spotlight as we head into 2026. With PCG 2021/4 now fully in effect as of 1 July 2024, the question is no longer if the ATO will review your arrangements, it is now a question of when. Is your firm ready?
The Full Federal Court has handed down its decision in AusNet Services Limited v Commissioner of Taxation. AusNet argued that its 2015 restructure did not qualify for rollover relief under Division 615, despite that it earlier said it did. This case serves as a reminder that once a tax election is made, it is very difficult to unwind. Careful planning and forecasting are critical.
Australia’s new thin capitalisation rules significantly impact businesses with foreign ownership or offshore operations. If your business has debt deductions (such as interest deductions and borrowing costs) of more than A$2m, tax deductions could be denied under the primary ‘earnings tests’ (particularly if your EBITDA is low or negative due to early-stage losses, especially common in sectors like infrastructure and technology).
To manage the above risk, the legislation offers an alternative test: the Third Party Debt Test (TPDT).
Australia has commenced reforming its Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF) regime including the ‘Tranche 2’ reforms, which expand AML/CTF compliance to apply to additional professions including lawyers.
Recent findings from the Family Business Report 2025 reveal that cash-flow management and economic uncertainty are the most pressing concerns for businesses in the construction and real estate sectors.
A global perspective on evolving real estate and construction markets, focusing on housing affordability, emerging asset classes, and sustainability. Gain insights from Grant Thornton’s experts across Australia and the UK help leaders navigate uncertainty and adapt investment strategies.
From 2026, Victoria’s VRLT will apply to long-term undeveloped land in metro Melbourne, targeting land banking and encouraging residential development. The expansion follows 2025 reforms aimed at improving housing affordability and supply.
Australia has commenced reforming its Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF) regime including the ‘Tranche 2’ reforms, which expand AML/CTF compliance to apply to additional professions including real estate agents and conveyancers.
In this episode of Beyond the Numbers with Grant Thornton, Management Consulting Partner, Richard Bycroft, and Director, Primo Danieletto, discuss automation in supply chains, triggers for reviewing an organisation’s current model and the ROI businesses can see from implementation.
Australian consumers are demanding more from retailers – better value, faster service, and consistently high quality. Discover what drives Australian retail and how to meet rising expectations.
The Federal Court’s $5.8M ACL decision signals a new era for privacy, cybersecurity, and governance in Australia. It reinforces that privacy and cyber obligations start Day 1 of any acquisition, governance failures will be scrutinised, and accountability cannot be outsourced. Boards must ensure robust oversight, deep cyber due diligence, and forensic incident response. With OAIC escalating regulatory enforcement, organisations face heightened legal, financial, and reputational risks.
In this episode, National Head of Corporate Finance & M&A Partner Holly Stiles and National Head of Technology, Media & Telecommunications and Private Business Tax & Advisory Partner Jace Gawne-Buckland discuss the current technology landscape in Australia, evolving expectations of investors, and tangible steps tech leaders can take to strengthen their position for future raises or exits.
Explore strategies for scaling in Australia’s tech and SaaS sector in this report, covering capital raising, investor expectations, and long-term growth.
At Grant Thornton we do things differently because we understand that when you strive for better and care about what you do remarkable things are possible.
The compelling client experience we’re passionate about creating at Grant Thornton can only be achieved through our people. We’ll encourage you to influence how, when and where you work, and take control of your time.
At Grant Thornton, we strive to create a culture of continuous learning and growth. Throughout every stage of your career, you’ll to be encouraged and supported to seize opportunities and reach your full potential.
To be able to reach your remarkable, we understand that you need to feel connected and respected as your authentic self – so we listen and strive for deeper understanding of what belonging means.
We’re passionate about making a difference in our communities. Through our sustainability and community engagement initiatives, we aim to contribute to society by creating lasting benefits that empower others to thrive.
As a new graduate, we aim to provide you more than just your ‘traditional’ graduate program; instead we kick start your career as an Associate and support you to turn theory into practice.
On 5 January 2026, the OECD released the ‘Side‑by‑Side’ package, introducing new and extended safe harbours for Pillar Two.
The package simplifies compliance and clarifies how Pillar Two interacts with the US minimum tax system, especially for US-headed groups.
From 2026, it offers streamlined ETR and top‑up tax mechanisms while leaving 2024–25 filing obligations unchanged.
On 5 January 2026, the Organisation of Economic Cooperation and Development (OECD)/G20 Inclusive Framework (the OECD) announced the ‘Side-by-Side’ administrative guidance package (SbS Package).
This introduces new safe harbours and extends existing safe harbours in a bid to reduce the compliance burden for Multinational Enterprises (MNE) that are in-scope of the Pillar Two rules.
The Package introduces new safe harbours, extends transitional measures, and provides further guidance that will influence how multinational groups prepare for compliance from December 2026 onward.
The Package aims to streamline compliance, reduce duplication where domestic minimum tax regimes already apply and provide clarity regarding the interaction between Pillar Two and the United States minimum tax system. For many multinational groups – particularly those with United States head entities – this represents a meaningful shift in how top-up taxes will be assessed and allocated.
Key takeaways
The SbS Package delivers five key outcomes – here are the key takeaways:
A series of simplification measures aimed at reducing compliance and reporting burdens for both MNEs and tax authorities when calculating effective tax rates (ETRs) and top‑up taxes under the GloBE rules.
Further alignment in the treatment of tax incentives globally, through the introduction of a targeted Substance‑Based Tax Incentive (SBTI) safe harbour.
New safe harbours for MNE groups with an ultimate parent entity (UPE) located in an eligible jurisdiction that meets minimum taxation requirements.
An evidence‑based stocktake process to ensure that the SbS framework maintains a level playing field for all Inclusive Framework members over time.
Reinforcement of the importance of Qualified Domestic Minimum Top-up Tax Returns (QDMTRs) as a key mechanism within the global minimum tax framework for safeguarding domestic tax bases.
The changes will not impact filings in respect of the 2024 and 2025 income years and groups should continue to take steps to ensure they meet the 30 June 2026 filing deadline.
Groups which qualify for the SbS safe harbour will still be required to file the GloBE Information Return (GIR) and QDMTR in jurisdictions which have implemented the rules.
Background: why a ‘side‑by‑side’ solution?
The United States has not adopted the OECD’s Pillar Two rules in their standard form. Instead, it operates a set of domestic and worldwide minimum tax rules that the US considers to be broadly consistent with the Pillar Two policy intent. Together with its G7 allies, the US advocated for ‘side‑by‑side’ model, under which Pillar Two would operate in parallel with the US minimum tax regime, rather than displacing it.
Agreement on the SbS Package was reached in return for the US withdrawing its proposed retaliatory ‘revenge tax’, which would have imposed punitive measures on jurisdictions applying Pillar Two top‑up taxes to US‑headed groups. The result is a framework designed to reduce the risk of double taxation and excessive compliance costs, while maintaining the integrity of the global minimum tax system.
The Package groups the items by the following areas:
a. SbS Safe Harbour
The SbS safe harbour allows Constituent Entities (CEs) whose UPE is located in a jurisdiction with a sufficiently robust domestic and worldwide tax system (a Qualified SbS Regime), as listed on the OECD Central Record) to be exempt from the Income Inclusion Rule (IIR) and the Undertaxed Profits Rule (UTPR). Importantly, the QDMTR continues to apply in all jurisdictions that have implemented it.
Broadly, a jurisdiction will qualify as having a Qualified SbS Regime where it demonstrates:
a nominal corporate income tax rate of at least 20 per cent
a QDMTT or alternative minimum tax of at least 15 per cent
an eligible worldwide tax system applying to offshore income of foreign branches and controlled foreign companies (both active and passive)
mechanisms to address base erosions and profit shifting and
no material risk of an effective tax rate below 15 per cent on domestic or foreign profits.
Application of the SbS safe harbour is elective and must be made in the group’s GIR. It does not apply automatically.
The SbS safe harbour applies for income years commencing on or after 1 January 2026.
Grant Thornton comment: At present, only the United States is listed on the OECD Central Record as having a Qualified SbS Regime. As a result, for US‑headed groups, neither the IIR nor the UTPR will apply from income years commencing on or after 1 January 2026.
b. UPE Safe Harbour
The UPE safe harbour applies where the UPE is located in a jurisdiction with a sufficiently robust domestic tax system (a Qualified UPE Regime), but that jurisdiction does not meet the additional worldwide tax system criteria required for the SbS safe harbour.
Under this safe harbour:
top‑up tax for all entities in the UPE jurisdiction is deemed to be nil for UTPR purposes only
other jurisdictions may still apply the IIR or UTPR to subsidiaries located outside the UPE jurisdiction
the UPE safe harbour replaces the transitional UTPR safe harbour, which expired on 31 December 2025.
The UPE safe harbour applies for income years commencing on or after 1 January 2026.
Grant Thornton comment: As at the date of release, no jurisdiction has yet been recognised as having a Qualified UPE Regime.
The SBTI safe harbour is designed to neutralise top‑up tax outcomes that would otherwise arise from certain Qualified Tax Incentives (QTIs), such as tax credits, super‑deductions, qualifying exemptions and preferential rates, subject to strict substance‑based caps.
Where an MNE group elects to apply the SBTI safe harbour:
QTIs are treated as an increase to the ETR numerator (adjusted covered taxes) based on their deemed tax value
QTIs are excluded from the ETR denominator, increasing the overall effective tax rate.
The uplift to the ETR numerator is capped at the greater of:
5.5 per cent of eligible payroll costs or eligible tangible asset depreciation or
1 per cent of the carrying value of eligible tangible assets.
The SBTI safe harbour applies for income years commencing on or after 1 January 2026.
Grant Thornton comment: While conceptually welcome, the SBTI safe harbour operates within a tightly defined and highly conditional framework. In practice, it is neither particularly generous nor simple to apply, and careful modelling will be required.
a. Simplified ETR Safe Harbour
The Simplified ETR safe harbour introduces a permanent, alternative method for determining whether a tested jurisdiction has top‑up tax exposure, provided that no top‑up tax arose in that jurisdiction in the preceding two years.
Key features include:
application on a tested jurisdiction basis, rather than entity‑by‑entity
top‑up tax is deemed to be zero where the simplified ETR is at least 15 per cent
calculations are based primarily on financial reporting data used in preparing the group’s consolidated financial statements.
Despite its name, the simplified ETR calculation still requires multiple adjustments, including basic, industry‑specific, conditional and optional adjustments and differs to the simplified ETR under the Transitional CbCR safe harbour.
The Simplified ETR safe harbour generally applies for income years commencing on or after 1 January 2027, although limited early application from 1 January 2026 is possible.
Grant Thornton comment: The Simplified ETR safe harbour remains highly technical and data‑intensive. While it may reduce complexity relative to the full GloBE calculation, it still demands substantial systems readiness and data quality.
b. Extension of the Transitional Country by Country Reporting (CbCR) safe harbour
The SbS Package extends the Transitional CbCR safe harbour by an additional year, from three years to four years.
The extension covers income years beginning on or before 31 December 2027 and ending on or before 30 June 2029.
The applicable safe harbour rate for the additional year remains 17 per cent.
Grant Thornton comment: This extension is a welcome development, giving MNEs additional time to enhance systems and processes required for full Pillar Two compliance.
The OECD stocktake and why it matters
The SbS Package introduces an evidence based stocktake that will periodically assess whether the safe harbours continue to operate consistently across jurisdictions. The stocktake will review whether jurisdictions listed as Qualified Regimes still meet the relevant criteria and whether the outcomes remain aligned with the intent of the global minimum tax.
Grant Thornton comment:
The stocktake reinforces that the safe harbours are not permanent. Jurisdictions may be added or removed over time, and multinational groups will need to monitor the OECD Central Record to ensure they are applying the correct treatment for each reporting year.
Australian implications
Amendments to the Australian domestic Pillar Two rules to reflect the SbS Package are expected in due course. However, Australian legislation already requires the Pillar Two rules to be interpreted consistently with OECD Administrative Guidance.
The SbS Package does not apply retrospectively. Full Pillar Two compliance remains required for income years 2024 and 2025.
Importantly:
CEs remain subject to QDMTR even where the UPE qualifies for the SbS safe harbour
the SbS and UPE safe harbours do not remove Australian Pillar Two filing obligations
significant penalties may apply for non‑compliance, even where no top‑up tax ultimately arises.
While Australia and other jurisdictions may seek recognition as Qualified SbS or Qualified UPE regimes in the future, the registration and review process may be lengthy. Taxpayers should not rely on this outcome until formally confirmed in the OECD Central Record.
What MNE groups should do now
MNE groups should now:
assess whether they may be eligible for the SbS or UPE safe harbours from 1 January 2026
actively monitor the OECD Central Record, as eligibility depends entirely on whether the UPE jurisdiction is listed as having a Qualified SbS or UPE Regime
continue investing in systems and data capabilities to support the Simplified ETR safe harbour and broader Pillar Two compliance
review the availability and impact of QTIs to determine whether the SBTI safe harbour could mitigate incremental top‑up tax exposure.
We’re here to help
Please reach out to our team of experts today to discuss any of the above.
Learn more about how our Tax services can help you
On Jan. 5, 2026, the OECD Inclusive Framework released significant administrative guidance, dubbed the side-by-side package, intended to resolve long-running uncertainty over how the Pillar 2 Global Anti-Base Erosion (GloBE) rules will apply to U.S. multinational enterprise (MNE) groups.
Pillar 2 tax law became effective Jan. 1 in the European Union and many other countries, and the new rules are generally applicable to multinationals with a turnover of more than 750 million euros.
Subscribe now to be kept up-to-date with timely and relevant insights, unique to the nature of your business, your areas of interest and the industry in which you operate.
