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By: Daniel Kave, Jessica Brass
28 Jan 2026 3 min read
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.
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
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.
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.
New Payday Super legislation addresses concessional contributions cap issues for 2026/27, but salary sacrifice and early payments remain key concerns.
The Government has introduced legislation for a minimum 30% tax on discretionary trusts from 1 July 2028. While some stakeholder feedback has been adopted, significant concerns remain around flexibility, complexity and the impact on private groups and SMEs.
Learn about the Federal Court decision around car parking fringe benefits for employers outside the CBD areas. Discover our recommendations in light of this decision. Stay informed to ensure accurate FBT returns in 2027.
