Significant foreign resident CGT reforms: draft legislation released
Client AlertForeign resident CGT reforms expand taxable Australian real property, withholding and renewables discount.
Congratulations to our new Partners and Principal. Read more now.
Aliece partners with mid-sized businesses providing Australian taxation compliance and advisory services.
Aliece has over 13 years of experience advising on a wide variety of tax issues, she has also developed a deep understanding of commercial and operational issues in relation to restructures, international tax, M&A activities, and tax consolidation.
Foreign resident CGT reforms expand taxable Australian real property, withholding and renewables discount.
PepsiCo embedded royalties, ATO Decision Impact Statement, embedded royalties Australia, royalty withholding tax, diverted profits tax, intellectual property payments, IP arrangements Australia, multinational tax Australia, ATO royalties guidance
On 30 October 2025, the Federal Court (Hespe J) handed down its decision in YTL Power Investments Limited v Commissioner of Taxation, finding for the Applicant and providing important guidance on the interpretation of ‘taxable Australian real property’ under Division 855 of the Income Tax Assessment Act 1997 (Cth) (ITAA 1997).