ATO raises the evidence bar for treaty claims through fiscally transparent entities
Client alertATO guidance increases evidence requirements for treaty claims through FTE structures.
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The global opportunities for businesses across all industries are vast, but with this also comes increased scrutiny and complexity around their approach to international tax. Every jurisdiction you wish to invest in has its own unique set of tax rules and obligations. As your international footprint grows, you must fulfil multiple – sometimes overlapping – tax rules within these countries, while also navigating increasingly regulated cross-border tax laws.
Grant Thornton has a strong track record of helping our clients manage their international tax obligations across multiple jurisdictions. We work with business leaders and decision-makers to understand and meet their tax obligations for the jurisdictions in which they operate, while ensuring all structures and plans are coordinated, with a focus on efficiencies.
We work with clients at the outset of their global expansions, as well as multinational organisations, who continue to be under the spotlight of tax authorities around the world. We are part of a global network across more than 140 countries, which means we stay across the latest international tax developments affecting your investments and future plans. We understand what it means to manage tax issues across multiple jurisdictions, and create innovative and effective strategies to address complex challenges.
Grant Thornton’s Corporate Tax team offer a suite of services to support Australian tax compliance requirements, including (but not limited to) preparation of annual income tax returns, Controlled Foreign Company (CFC) calculations, Hybrid Mismatch Analysis, corporate tax residency analysis and withholding tax calculations and filing obligations.
Whether you're a foreign business entering the Australian market or an Australian business expanding overseas, navigating cross-border tax obligations requires careful planning. Our specialists provide practical, commercially focused advice on structuring, governance, compliance and tax risk, helping you manage complexity, seize opportunities and support sustainable growth across multiple jurisdictions.
Grant Thornton’s Global Trade and Customs team helps clients optimise tariffs, review customs duties embedded within the supply chain and assist with customs compliance obligations.
Transfer pricing is one of the most complex and scrutinised areas of international tax. Grant Thornton helps multinational businesses manage every stage of the transfer pricing lifecycle from strategy, documentation to audit defence. Our experienced team delivers practical solutions that support business growth in an increasingly complex global tax environment.
The new Pillar Two rules are aimed at ensuring large MNE are subject to a minimum effective tax rate of 15 per cent. Grant Thornton’s Pillar Two specialists can assist you in determining whether the Pillar Two rules apply to your business and if so, help you navigate the Australian Pillar Two compliance obligations.
Our global mobility team works with expatriates and their employers to create effective tax plans for accessing the extended talent pool key to your business success.
Grant Thornton’s Corporate Tax team offer a suite of services to support Australian tax compliance requirements, including (but not limited to) preparation of annual income tax returns, Controlled Foreign Company (CFC) calculations, Hybrid Mismatch Analysis, corporate tax residency analysis and withholding tax calculations and filing obligations.
Transfer pricing is one of the most complex and scrutinised areas of international tax. Grant Thornton helps multinational businesses manage every stage of the transfer pricing lifecycle from strategy, documentation to audit defence. Our experienced team delivers practical solutions that support business growth in an increasingly complex global tax environment.
Whether you're a foreign business entering the Australian market or an Australian business expanding overseas, navigating cross-border tax obligations requires careful planning. Our specialists provide practical, commercially focused advice on structuring, governance, compliance and tax risk, helping you manage complexity, seize opportunities and support sustainable growth across multiple jurisdictions.
The new Pillar Two rules are aimed at ensuring large MNE are subject to a minimum effective tax rate of 15 per cent. Grant Thornton’s Pillar Two specialists can assist you in determining whether the Pillar Two rules apply to your business and if so, help you navigate the Australian Pillar Two compliance obligations.
Grant Thornton’s Global Trade and Customs team helps clients optimise tariffs, review customs duties embedded within the supply chain and assist with customs compliance obligations.
Our global mobility team works with expatriates and their employers to create effective tax plans for accessing the extended talent pool key to your business success.

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ATO guidance increases evidence requirements for treaty claims through FTE structures.
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Whether you're growing across borders, managing global operations or responding to changing tax regulations, our International Tax specialists can help you navigate complex global tax challenges. Complete this form and we'll connect you with the right expert to discuss your business needs.
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