Now that the Prime Minister has called an election for 3 May 2025, it is opportune to look back on the tax-related developments of the 47th Parliament. What did the Parliament and in particular, the Albanese Labor government achieve on multinational tax matters in its 2022-2025 term?

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Australia's corporate landscape is set to undergo a significant change with the government's commitment to establish a beneficial ownership register. This significant reform intends to shine a light on the underlying ownership of Australian companies, making previously private information accessible first to regulators, journalists and academics, and later to the broader public.

No timing has yet been announced as to the start date of the regime.

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On 10 December 2024, the legislation implementing the global and domestic minimum tax in Australia received royal assent and on 23 December 2024, the legislative instrument containing the substantive rules was registered by the Treasurer. This cements substantive enactment, a timely milestone for year-end financial reporting. 

Our latest Tax Insight provides initial observations on the final Pillar Two rules and tips for tax teams.

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On 10 December 2024, the much anticipated public country-by-country reporting measures received Royal Assent. 

The public CbC reporting measures affect certain multinational entities that operate in Australia by requiring the public release of certain tax and other information on a jurisdiction-by-jurisdiction basis together with a statement on their approach to taxation, for reporting periods starting on or after 1 July 2024.

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On 12 December 2024, the Australian government announced the introduction of a “News Bargaining Incentive” to incentivize commercial deals between digital platforms and news businesses. Consultation on the incentive will begin in early 2025, with legislation to follow after the election, which is due in the first half of 2025.

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On 4 December 2024, the Australian Taxation Office issued PCG 2024 / D4 dealing with the ATO’s compliance approach to “capital raised for the purpose of funding franked distributions”. 

The Draft PCG sets out a green / low risk zone and a red / high risk zone, and also acknowledges that there is effectively a “grey zone” where an arrangement will not be categorised by the PCG as either low risk or high risk.

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On 29 November 2024 the Australian parliament passed legislation to improve housing affordability through tax incentives for certain build to rent developments, as part of the government's broader plan to increase housing supply in Australia.

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On 27 November 2024, the Australian Taxation Office released the following guidance:

• TD 2024/9 Income tax: factors taken into account applying paragraphs 99B(2)(a) and (b) of the Income Tax Assessment Act 1936; and
• PCG 2024/3 Section 99B of the Income Tax Assessment Act 1936 – ATO compliance approach

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On 9 October 2024, the Australian Taxation Office released long-awaited guidance in the form of a draft practical compliance guideline titled PCG 2024/D3 Restructures and the new thin capitalisation and debt deduction creation rules.

Our latest Tax Insight provides initial observations on the key features of the proposed ATO guidance. 

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On 4 July 2024, Australia made a further step towards the implementation of Pillar Two, introducing the Bills into Parliament with accompanying Explanatory Memorandum in respect of Pillar Two Primary Legislation.

The Tax Insight provides our key observations that are relevant for Australian taxpayers.

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On 26 June 2024, the Full Federal Court handed down a 2-1 majority decision in favour of the taxpayer in PepsiCo, Inc v Commissioner of Taxation [2024] FCAFC 86. The decision overturned the November 2023 first instance decision which upheld the Commissioner’s position.

This is a significant case given the ATO focus on intangible arrangements and in as much as it provided the most authoritative judicial analysis to date of both the Diverted Profits Tax (DPT) and 2012 amendments to the Australian GAAR following an earlier series of Court decisions on Part IVA that went against the Commissioner. 

The Tax Insight provides our initial preliminary comments on the decision. 

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On 5 June 2024, the Australian Government introduced a new Bill into Parliament: Treasury Laws Amendment (Responsible Buy Now Pay Later and Other Measures) Bill 2024, which contains various measures including Public Country by-Country Reporting (Public CbC Reporting) at Schedule 4. 

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On 8 April 2024, the Treasury Laws Amendment (Making Multinationals Pay Their Fair Share—Integrity and Transparency) Bill 2023 (Multinational Tax Bill or Bill) which introduces the new interest limitation rules received Royal Assent.

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