Tax insights

On 5 January 2026, the OECD/G20 Inclusive Framework on BEPS (“inclusive framework”) published details of a “side-by-side package” in relation to the Pillar Two global minimum tax rules (“Pillar Two”).

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Latest ATO guidance

New ATO guidance covers some of the practical issues raised by stakeholders to date and provides much needed instruction as we rapidly head into the first lodgement season for Pillar Two.

This article summarises the new guidance as well as a recap on what has been
released to date.

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On 5 December 2025, the ATO released a PS LA 2025/2 Public Country-by-Country (CbC) reporting exemptions which finalised the previously released draft PS LA 2025/D1.

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On 10 December 2025, the ATO released draft Practical Compliance Guideline PCG 2019/DC1, which is a draft consolidation for comment, outlining proposed changes to PCG 2019/1 Transfer pricing (TP) issues related to inbound distribution arrangements, to ensure the ATO’s profit markers for assessing transfer pricing risk remain relevant and up to date.

Set out in this Tax Insight are the key changes proposed in PCG 2019/1DC compared to the original PCG 2019/1, as well as Deloitte’s observations on practical implications for inbound distributors to consider.

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The YTL Power and Newmont decisions of the Federal Court of Australia provide critical guidance, with particular relevance to the power and utilities sector and infrastructure more broadly. Both judgments apply a consistent interpretative approach to Division 855. Further details on the context, background and detail of these decisions are highlighted in this Tax Insight.

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