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Foreign investors in the firing line: Treasury’s expanded CGT regime

21/04/2026

Treasury is proposing a significant expansion of Australia’s foreign resident capital gains tax (CGT) regime, materially increasing the tax exposure and exit risk for foreign investors with Australian land‑connected assets. Treasury has released draft legislation that would materially widen the scope of assets subject to Australian capital gains tax by broadening the definition of taxable […]

PDAs in public: When your property development arrangement gets the ATO’s attention

16/04/2026

The ATO has released Practical Compliance Guideline 2026/D2, outlining its risk framework for property development arrangements (PDAs), with a particular focus on long-term projects involving related parties and identifying what it considers high and low risk structures. Following public consultation and the release of Taxpayer Alert TA 2026/1, which we discussed in a previous alert here, this […]

How the ATO’s Fuel Response Plan can support your business in 2026

10/04/2026

On 30 March 2026, the Australian Government announced the National Fuel Security Plan. From 1 April 2026, the Australian Taxation Office (ATO) is administering several temporary measures, including a reduction in fuel excise duty by 32 cents per litre for 3 months, as well as changes to fuel tax credit rates. Effective from 1 April […]

SEPL case update: Ownership vs employment implications for fringe benefits tax

02/04/2026

The Full Federal Court has confirmed that no fringe benefits tax (FBT) is payable in the SEPL Pty Ltd case, restoring the Administrative Appeals Tribunal’s (AAT) earlier decision. This ruling is particularly significant for family‑owned and private business groups, as it clarifies how everyday arrangements can trigger, or avoid, substantial FBT exposure. The case emphasises […]

Supreme Court confirms landholder duty on appointment of director

23/03/2026

Taking control of a corporate trustee can trigger landholder duty, even without acquiring land or units. The Supreme Court of Victoria has confirmed that assuming full control of a trustee company may amount to acquiring ‘control’ of the underlying landholding trust under section 82 of the Duties Act 2000 (Vic). In Tao v Commissioner of […]

Division 296 tax has passed parliament and what it means for large super balances

19/03/2026

Division 296 has now become law, introducing an additional tax on superannuation earnings for individuals with very large super balances from 1 July 2026, with first assessments expected after 30 June 2027. The long-awaited Division 296 tax has now passed both houses of Parliament and received Royal assent, becoming law under the Treasury Laws Amendment […]

Superannuation contribution caps to increase from 1 July 2026

18/03/2026

From 1 July 2026, several key superannuation thresholds will increase due to indexation. These changes create additional opportunities for eligible individuals to make larger contributions to super in a tax-effective environment, particularly where non-concessional and bring-forward strategies are being considered. We summarise the main changes below and explain what they may mean for you. Contribution […]

Government announces changes to Private and Public Ancillary Funds (Giving Funds)

05/03/2026

The government will increase the minimum annual distribution rate while allowing funds to smooth distributions over a three-year period. The Federal Government has announced significant reforms to the regulation of Private Ancillary Funds (PAFs) and Public Ancillary Funds (PuAFs) as part of its broader objective to increase philanthropic giving in Australia. These changes flow from […]

Payday Super Regulations released: What employers need to know and why early action matters

04/03/2026

The Australian Government has released the Treasury Laws Amendment (Payday Superannuation) Regulations 2026, with two important changes for employers. Coming into effect from 1 July 2026, there will be an administrative uplift that rewards early action, and a much more limited power for the Commissioner to extend deadlines. The Treasury Laws Amendment (Payday Superannuation) Regulations […]

Full Federal Court denies deductions for transactions between related parties

03/03/2026

The Full Federal Court has ruled in favour of the Australian Taxation Office (ATO), disallowing deductions for transactions between related parties which were not documented adequately. In Commissioner of Taxation v S.N.A Group Pty Ltd [2026] FCAFC 10 a group of entities collectively referred to as the S.N.A Group carried on real estate businesses. The […]