Significant foreign resident CGT reforms: draft legislation released
Client AlertForeign resident CGT reforms expand taxable Australian real property, withholding and renewables discount.
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Elizabeth is a diligent problem solver and strives to cut through the noise to identify key issues when providing tax advice.
With experience spanning a diverse number of industries including tourism, agriculture, retail, education and health, Elizabeth is experienced in advising on both international and corporate taxation matters.
Elizabeth is adept at simplifying complexity to provide practical guidance and support to her clients, and enjoys getting to know her clients and their businesses.
Recent experience includes:
Foreign resident CGT reforms expand taxable Australian real property, withholding and renewables discount.
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.
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).