On 20 August 2025, the ATO released a final practical compliance guideline PCG 2025/2 titled Restructures and the thin capitalisation and debt deduction creation rules – ATO compliance approach. 

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On 13 August 2025, the High Court decided in favour of PepsiCo, Inc and Stokely-Van Camp, Inc in Commissioner of Taxation v PepsiCo, Inc [2025] HCA 30. This decision brings to an end the much-followed dispute involving PepsiCo in respect of the 2018 and 2019 years.

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On 6 August 2025, the Australian Taxation Office (ATO) released draft practical compliance guideline (PCG) PCG 2025/D4 Low-risk payments relating to software arrangements—ATO compliance approach (PCG 2025/D4).

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On 31 July 2025, Australia's Productivity Commission (PC) released the first of five scheduled interim reports in response to a request by the Australian Treasurer in December 2024 for the PC to undertake five inquiries to identify the highest priority reforms under the government’s five-pillar productivity growth agenda.

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Despite the political headwinds the OECD’s Pillar Two framework continues to face, Pillar Two is enacted legislation in Australia. In-scope groups must therefore continue their preparation to meet Australia’s Global Minimum Tax and Domestic Minimum Tax obligations.

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