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Tax insights

Latest developments in tax

Deloitte Australia’s Tax insights apply a wealth of expertise to provide you with comprehensive analysis and implications in respect of the latest tax developments.

Latest tax insight

Draft foreign resident CGT legislation would introduce retrospective law changes – 15 April 2026

On 10 April 2026, the Government released exposure draft legislation proposing changes to the foreign resident CGT regime that were first announced in May 2024 as part of the 2024–25 Federal Budget. Despite the importance and breadth of these changes, the consultation period closes on 24 April 2026.

The proposed changes include:

  • Retrospective amendments (from 12 December 2006) to the definition of TARP; and
  • A limited renewable energy concession, reducing the tax rate by 50% on certain qualifying disposals undertaken by foreign residents between commencement and 30 June 2030.


Recent tax insights

On 25 March 2026, Senator the Hon Tim Ayres addressed the National Press Club of Australia on “Smarter, Stronger, Safer: A Future Made in Australia backed by R&D”, building upon key messages from the much-anticipated Strategic Examination of Research and Development final report, “Ambitious Australia”, released on 17 March 2026.

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On 17 February 2026, the Full Federal Court released its decision in favour of the Commissioner in Commissioner of Taxation v. S.N.A Group Pty Ltd [2026] FCAFC 10 finding that around $19 million of inter-entity service fees paid during the tax years 30 June 2016 and 30 June 2019 were not deductible under s 8-1 of the Income Tax Assessment Act 1997 (Cth).

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On 24 March 2026, and after eight years of negotiations, Australia and the EU put pen to paper on a historic free trade agreement which will drive enhanced economic and people to people links between the EU and Australia.

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Division 296 tax is a new Australian tax on superannuation earnings for those individuals with a total superannuation balance of more than $3 million.

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On 3 March 2026, the ATO released final instructions to complete the public country-by-country (CbC) report. The instructions include information that must be included in an annual public CbC report, the level of detail expected in both quantitative and qualitative disclosures, the process for submission of the report to the ATO, and how to interpret and apply the legislation and accompanying guidance in practice.

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