Tax Insight: Signs of BEPS Life

The Inclusive Framework of the OECD/G20 has released an “Outcome Statement” on developments in the long-running BEPS project. The Statement is evidence of life for the BEPS project. It focuses on work done but not yet public, rather than announcing significant progress on achieving milestones, new developments or major departures from what was already in … Read more

Tax Insight: Government Introduces Thin Capitalisation Changes

The Government has introduced into the House of Representatives the Treasury Laws Amendment (Making Multinationals Pay Their Fair Share – Integrity and Transparency) Bill 2023 to enact its proposed changes to Australia’s thin capitalisation regime. This Tax Insight gives a brief summary of the key points; a fuller analysis will follow. Thin capitalisation changes So … Read more

Tax Insight – Australia’s Second Income Tax

The recent Budget contained only a few surprises but one important announcement was the confirmation of what many had already suspected: Australia will soon have a second income tax. In fact, it will start in just over 6 months. Australia will enact a so-called “qualified domestic minimum top-up tax” (“QDMTT”) as part of the suite … Read more

Tax Insight – Tax Measures in Australia’s 2023-24 Budget

So far as tax is concerned, the ALP’s second Budget served as a reminder of measures already in train and other measures selectively released to the press in the last few weeks. Even so, there were still a few tax surprises in store for the business community. Read more

Tax Insight – Another public tax reporting obligation

Treasury has released for consultation an Exposure Draft of new rules which will require multinational groups with an Australian presence to publish information about their tax and financial position for all the jurisdictions in which the group operates. Submissions on the Exposure Draft are due by 28 April 2023. 1. Background The Exposure Draft just … Read more

Tax Insight – New Limits on Deducting Payments Involving Intangibles

Treasury has released for consultation an Exposure Draft of new provisions which will, in some cases, deny large Australian businesses a deduction for amounts connected with intangibles if paid to associates. If enacted in their current form, the new rules would apply from 1 July 2023. Submissions on the Exposure Draft are due by 28 … Read more

Tax Insight: New limits on deducting interest

Treasury decided to spring a very big surprise on multinationals in an Exposure Draft released on 16 March 2023. The Draft was expected to address the Government’s promise to reconceptualise the thin capitalisation safe harbour from a debt: asset ratio to a percentage of EBITDA, which it does (a detailed analysis will follow). The Draft … Read more