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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.

Recent tax insights

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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On 21 March 2024, Treasury released the highly anticipated Exposure Draft legislation for the implementation of Pillar Two in Australia. The package of Exposure Draft legislation includes both primary and subordinate legislation, along with accompanying explanatory materials and a discussion paper for stakeholder consultation and feedback.  

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On 12 February 2024, the Australian Government released new draft legislation for certain multinational entities that operate in Australia to require 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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The ATO has finalised and released its compliance approach to intangibles migration arrangements involving international related parties in PCG 2024/1.

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On 17 January 2024, the Commissioner of Taxation (the Commissioner) withdrew Draft Taxation Ruling TR 2021/D4 (TR 2021/D4) and replaced it with an updated draft for public consultation, TR 2024/D1, “Income tax – royalties – character of payments in respect of software and intellectual property rights” (TR 2024/D1).

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The Government’s legislative process to introduce its new interest limitation laws, to be effective from 1 July 2023, has hit a significant roadblock. In the evening of 5 December 2023, the Treasury Laws Amendment (Making Multinationals Pay Their Fair Share—Integrity and Transparency) Bill 2023 with extensive government amendments was referred to the Senate Economics Legislation Committee for further consideration.  Parliament is scheduled to return on 6 February 2024, being the day after the Committee is due to report. The Bill is not expected to move any further pending the report from the Committee.

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On 15 November 2023, the Senate passed Treasury Laws Amendment (2023 Measures No. 1) Bill 2023 together with Government amendments to Schedule 5 - the Franked distributions funded by capital raisings measure. On 27 November 2023, the Bill, as modified by Senate amendments, received Royal Assent.

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Explore the archive of Tax insights below.


21 July 2023 - Pillar Two: OECD releases further materials

26 June 2023 - Australian multinational tax laws introduced

23 May 2023 - International intangibles arrangements

8 May 2023 - Proposed reforms to the Petroleum Resource Rent Tax

13 April 2023 - Thin capitalisation exposure draft legislation: Deloitte submission

11 April 2023 - Australia proposes public tax reporting for Australian and foreign headquartered multinationals

04 April 2023 - Exposure draft denying deduction for payments attributed to intangible assets issued

04 April 2023 - Australia’s transfer pricing rules unleashed

21 March 2023 - Exposure draft on new debt deduction rules

16 March 2023 - Franked distributions & capital raisings

15 February 2023 - OECD releases Pillar Two administrative guidance

30 January 2023 - OECD Pillar Two: Information return and safe harbours


01 December 2022 - Tax Transformation Trends

25 October 2022 - Federal Budget

13 September 2022 - Fringe benefits tax – Record keeping changes

5 September 2022 - Federal Court recognition of the commercial reality of small and privately owned businesses

08 August 2022 - The 2022 Indirect Tax Pathfinder - 08 August 2022

27 July 2022 - Government introduces legislation to encourage electric vehicle adoption

21 July 2022 - ATO releases Taxpayer Alert on treaty shopping arrangements

18 July 2022 - Update on EBITDA interest and royalty measures

30 June 2022 - Hybrid Mismatch Rules – US GILTI rules do not correspond to Australia’s CFC rules

10 June 2022 - ATO changing the way it obtains GST assurance for Top 1000 taxpayers

1 June 2022 - Changes to debt deduction rules

19 May 2022 - Corporate Tax Playbook

16 May 2022 - Notional GST: ATO’s dispute resolution approach for government entities

16 May 2022 - Understanding the post-election tax policies

29 March 2022 – Federal Budget 2022-23

1 March 2022 - New ATO guidance for private and family groups

31 January 2022 - ATO announces a review of the Advance Pricing Arrangement program

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