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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.
Payday Super regulations explained: how the new administrative uplift works and what employers must do next
In July 2025, we wrote about the Federal Court’s decision in S.N.A Group Pty Ltd v Commissioner of Taxation [2025] FCA 240, which was widely seen as a ‘commercial reality’ endorsement for inter entity service fee arrangements in closely held groups – where documentation is known to be imperfect.
What Australia’s Carbon Leakage Review means for trade, imports and business costs
