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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 […]

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: […]

Updates on the Big Beautiful Section 899 & Pillar Two 

02/07/2025

Never a dull moment in US politics and tax policies – the proposed section 899 has come and gone in a matter of weeks. What are the ramifications for Pillar Two?  Just few weeks after the US Congress passed the One Big Beautiful Bill Act (the OBBBA), including the controversial Section 899 ‘revenge tax’, the […]

Changes to deductibility of interests on ATO debts - Effective 1 July 2025

24/06/2025

General interest charge (GIC) and Shortfall Interest Charge (SIC) incurred from 1 July 2025 will no longer be deductible, increasing the after tax cost of carrying a tax debt.  Taxpayers have historically been able to claim tax deductions for GIC and SIC imposed by the ATO. This helped offset the financial burden of these penalty […]

Victoria’s State Tax Reform 2025: What Property Owners, Developers & Advisors Need to Know

04/06/2025

In May 2025, the Victorian Government introduced the State Taxation Acts Amendment Bill 2025 which provides various changes that will impact landowners, developers, trustees, and individuals navigating Victoria’s complex tax landscape. This article outlines the key changes, with commentary on practical implications, compliance requirements, and planning considerations for clients and advisors alike. The Bill and […]

Section 899: Not a Big Beautiful Tax

30/05/2025

On 22 May 2025, the United States (U.S.) House of Representatives passed section 899, a retaliatory and penalty tax targeting inbound investments to the U.S. by foreign entities from countries (including Australia) imposing ‘discriminatory taxes’ against U.S. entities. As part of the One Big Beautiful Bill Act (the Bill) passed by the U.S. House of […]

Build to Rent | State Taxes comparison

30/05/2025

Understanding Build-to-Rent (BTR) concessions across Australia can be complex — so we’ve broken it down to make it easier for you to compare the key differences and eligibility criteria in each State and Territory. This guide provides a clear, side-by-side comparison of BTR definitions, tax concessions, and access requirements across all Australian jurisdictions. If you’re […]