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.
ATO releases first Pillar Two guidance – take ‘reasonable measures’ to comply – 16 July 2025
On 16 July 2025 the Australian Taxation Office released draft guidance regarding global and domestic minimum tax lodgment obligations for the transitional period – the first administrative guidance released on the new Pillar Two rules that were introduced in Australia in 2024.
ATO issues draft guidelines for exemptions to public CbC reporting - 3 July 2025
On 3 July 2025, the ATO released a draft Law Administration Practice Statement PSLA 2025/D1 Public Country-by-Country reporting exemptions. The draft PSLA outlines the considerations, process and information relevant to the grant of full or partial exemptions from public Country-by-Country reporting.
Unpacking the Alcoa transfer pricing case – 23 June 2025
On 30 April 2025, the new Administrative Review Tribunal handed down its decision on a transfer pricing case between the Commissioner of Taxation and Alcoa of Australia Ltd.
Post election tax policies of the Albanese Labor government – 19 May 2025
This Tax Insight summarises what business can otherwise expect beyond the election from the government elect and the Greens given their influence in the Senate.
Multinational taxation and the 47th Parliament – 15 April 2025
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?
A new frontier of transparency for private groups – 22 January 2025
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.
Australia enacts Pillar Two legislation – 7 January 2025
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.
Australian Government passes public country-by-country reporting measures – 18 December 2024
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.
News Bargaining Incentive proposed to ensure sustainability of news media – 16 December 2024
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.
Draft PCG on franked distributions funded by capital raisings– 9 December 2024
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.
Build to rent measures pass through both houses of parliament – 9 December 2024
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.
Compliance approach to restructures under the DDCR – 11 October 2024
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.
Pillar Two primary legislation - Bills introduced - 9 July 2024
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.
Full Federal Court rules in favour of PepsiCo – 28 June 2024
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.
Australian Government introduces Public Country-by-Country Reporting Bill – 6 June 2024
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.
New interest limitation rules finally passed: operative from 1 July 2023 - 9 April 2024
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.
