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Capital gains tax changes: what they mean for your transaction strategy
InsightNew CGT reforms reshape M&A, valuations and exit planning. Understand the key implications.
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:
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.
Turning tax strategy into an advantage
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.
Authors
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Daniel Kave
Daniel, with vast experience, specialises in advising public companies and large private groups on complex tax matters including tax consolidations, M&A structuring, due diligence, corporate structuring, tax planning, capital gains tax, and international tax. He serves multinational organizations and advises businesses in retail, franchising, manufacturing, and mining.View Profile -
Jessica Brass
Jess is an experienced corporate tax adviser, having worked in both Australia and the UK. She manages a broad client portfolio, from domestic start-ups to large, international groups. Her clients span a range of industries, with specific focus on real estate & construction and energy & resources.View Profile
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