Quick summary
  • The year 2025 marked a transformative year for Australia’s international tax landscape, with multiple legislative reforms, judicial decisions and ATO guidance – reshaping how multinational groups are taxed in Australia.  
  • Major global initiatives moved from concept to implementation, including the enactment of Pillar Two and Australia’s Public Country-by-Country reporting regime – both signalling a decisive shift towards stronger tax integrity and transparency expectations for large multinationals. 
  • Alongside these reforms, the ATO intensified its technical guidance and compliance activity, and several significant court decisions further clarified Australia’s approach to cross‑border taxation issues. 
Australia’s international tax rules are evolving – creating new compliance obligations and strategic considerations to multinational businesses with an Australian presence.

From the introduction of Pillar Two to increased debt deduction limitations and public reporting obligations, the international tax landscape is shifting rapidly. These changes influence how businesses structure financing, manage risk, and plan for sustainable growth – and the decisions you make today will shape outcomes for years to come. Combined with several high‑profile court decisions, the year underlined that staying ahead of international tax developments is no longer optional for businesses operating across borders.

Key developments shaping the landscape:

Australia’s Pillar Two rules implement a 15 per cent global minimum tax for large MNEs from income years starting 1 January 2024. Businesses in scope face new ATO filing obligations and potential top‑up tax payments, with first filing due on 30 June 2026. Early planning ensures you can manage both compliance and cash flow impacts. Read more

Effective 1 July 2024, the DDCR permanently deny interest deductions for certain related‑party debt, with no transitional relief. For companies with cross-border financing, this means reviewing structures and preparing for new 2025 disclosure obligations. Read more

From 1 July 2024, Australia’s public CbCR regime requires large multinationals to disclose jurisdiction‑level tax and financial data, with first reports due June 2026. The move to public transparency adds both new compliance, commercial and reputational considerations to international operations. Read more

The PepsiCo case showed that genuine goods‑only supply arrangements are less likely to be recharacterised as embedded royalties, reducing exposure to royalty withholding tax and Diverted Profits Tax. Read more

Your guide to navigating change

Our latest Australian International Tax Newsletter brings together the key developments, practical insights, and emerging risks from 2025 – helping businesses make informed decisions across borders.

Australian international tax: 2025 recap
Newsletter

Australian international tax: 2025 recap

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Understanding how recent international tax changes affect your operations will help you manage risk, optimise structures, and seize growth opportunities. Reach out to our experts for tailored guidance to turn complexity into strategic advantage.

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