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Victorian State Revenue Office clarifies land transfer duty on economic entitlements  

16/09/2025

The Victorian State Revenue Office (SRO) has provided some clarity on how service fees and beneficial ownership calculations impact land transfer duty obligations. With the rulings to take effect from 1 July 2025, the Victorian SRO issued draft revenue ruling DA-067 and final versions of revenue rulings DA-065 and DA-066 which consider the treatment of […]

Payroll tax and the gig economy: Uber seeks High Court appeal 

12/09/2025

Uber submits application to appeal the decision in Chief Commissioner of State Revenue v Uber Australia Pty Ltd [2025] NSWCA 172 which confirmed driver payments (2015–2020) were taxable wages, leaving Uber with over $81 million in payroll tax liabilities. What has happened On 1 August 2025, the Court of Appeal unanimously held that Uber’s payments […]

Preparing for Pillar Two | CTS Pillar Two

05/09/2025

If you’re part of a multinational enterprise group operating in Australia, new Global and Domestic Minimum Tax (Pillar Two) lodgement requirements are on the horizon. From 30 June 2026, Australian subsidiaries, consolidated groups, and joint ventures will need to determine whether they fall within scope, and when exemptions apply. At SW, we’re already helping clients […]

ATO releases exemptions for Australian domestic Pillar Two forms

03/09/2025

The ATO has released draft Legislative Instrument LI 2025/D17, which specifies when certain entities are exempt from lodging domestic Pillar Two forms. However, this exemption does not apply to the Global Information Return (GIR). The purpose of the instrument is to help multinational enterprise groups reduce compliance costs by removing the need to lodge certain […]

Payment

28/08/2025

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The Commissioner v PepsiCo: A turning point in intellectual property and royalty characterisation

26/08/2025

The High Court has handed down its long-awaited decision in Commissioner of Taxation v PepsiCo, Inc [2025] HCA 30 (PepsiCo), with a 4–3 majority finding in favour of the Taxpayer in the protracted ‘embedded’ royalty dispute with the Commissioner. The High Court has, by a 4-3 majority, dismissed the Commissioner’s appeal ruled in favour of […]

Pillar Two obligations in Australia during the transition period

22/08/2025

The ATO released new guidance helping large multinational companies navigate their obligations under Pillar Two tax rules. While these companies face additional paperwork and potential penalties, the ATO is taking a lenient approach during the transition period for businesses making genuine compliance efforts. Overview Draft Practical Compliance Guideline PCG 2025/D3 outlines the ATO’s transitional compliance […]

AML/CTF penalties offer critical lessons for community clubs 

21/08/2025

The regulator AUSTRAC has launched civil penalty proceedings against an NSW community club for serious and systemic non-compliance with Australia’s Anti-Money Laundering and Counter-terrorism Financing (AML/CTF) requirements.  Weaknesses of the AML/CTF program: Each contravention attracts a maximum civil penalty between $21m and $31.3m.  Key learnings include:  How SW can help SW will continue to monitor […]

Feedback on Treasury’s Giving Fund reforms

07/08/2025

Our submission to the Government’s consultation paper reflects feedback raised by trustees of affected Funds on the proposed increase to the minimum distribution rate. Based on our discussions, trustees are concerned that the change is inconsistent with their Funds’ objective of providing long-term charitable support. The Treasury has released a consultation paper ‘Giving fund reforms: […]

Emerging Property Fund Managers’ Series

21/07/2025

Developing tomorrow’s leaders today For the eighth year, we are delivering an interactive 5-part seminar series to aspiring and emerging leaders in the Property and Real Estate Credit Funds Management sectors, with direct access to leading industry experts and their experience, strategic industry insights and pitfalls, and key issues ranging from structuring, debt and equity […]