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What the ATO’s finalised software royalties ruling & draft guidance means for businesses

11/09/2026

The Australian Taxation Office (ATO) recently issued TR 2026/2, which sets out its view on when payments relating to software and intellectual property rights may constitute royalties for Australian tax purposes. At the same time, the ATO released draft PCG 2026/D4, which provides a practical compliance framework to help taxpayers assess the ATO’s likely level […]

Treasury releases exposure draft on the 30% minimum tax on discretionary trusts

07/09/2026

The Federal Government has released exposure draft legislation to implement its proposed 30% minimum tax on discretionary trusts, announced in the 2026-27 Federal Budget. The package includes three interconnected measures: The draft provisions represent one of the most significant trust taxation reforms in decades and will require many family groups to assess whether their existing […]

The ATO’s draft tax guidance on crypto airdrops & wrapping

03/09/2026

The Australian Taxation Office (ATO) has released Draft Taxation Ruling TR 2026/D1 and Draft Taxation Determination TD 2026/D2, setting out its preliminary views on the income tax treatment of crypto asset airdrops and the capital gains tax (CGT) consequences of wrapping and unwrapping crypto assets. The draft guidance may affect crypto asset businesses, investors, and […]

Navigating the new requirements for Payday Super

27/08/2026

Payday Super is here, bringing new compliance demands for employers. With the changes in effect from 1 July 2026, organisations must consider whether their payroll processes and systems are ready to meet the new requirements. Join us for one of two practical sessions to understand what Payday Super means for your organisation and where issues […]

Discretion advised on the 30% trust tax, $10m CGT lifeline & startup sweeteners

24/08/2026

The Federal Government has released further detail on its tax reform package, providing greater clarity on measures affecting small businesses, startups, and trust structures. These updates provide further clarity on the 2026–27 Federal Budget reforms, outlining how key measures will operate in practice, as set out in the Government’s tax reform implementation announcement and legislated […]

Trust in the detail: SW calls for a fairer 30% minimum tax on discretionary trusts

31/07/2026

SW has lodged a submission with Treasury (read here) on the proposed 30% minimum tax on discretionary trusts, urging targeted changes to prevent ‘fixed’ commercial structures being swept in and to remove a punitive 60% double-tax on corporate beneficiaries. Introduction In the 2026–27 Federal Budget, the Government announced a 30% minimum tax on discretionary trusts, […]

Know your consumer: ATO’s new draft ruling for GST cross-border supplies

18/06/2026

On 10 June 2026, the ATO released draft ruling GSTR 2026/D1 (‘the ruling’) which is intended to replace GSTR 2017/1. The draft ruling provides updated guidance on determining when an overseas supplier is making cross-border supplies of services, digital products, or rights to an ‘Australian consumer’ and, therefore, making supplies connected with Australia for GST […]

ATO finalises guidance on when ancillary funds ‘provide a benefit’

17/06/2026

Following our earlier analysis of draft Taxation Determination TD 2025/D3, the Australian Taxation Office (ATO) has now finalised its guidance with the release of Taxation Determination TD 2026/3. The determination confirms the ATO’s view on when an ancillary fund ‘provides’ a benefit and provides further clarification on the role of legally binding commitments when assessing […]

Division 7A update: High Court confirms Bendel decision on UPEs

12/06/2026

The High Court has now handed down its decision in Commissioner of Taxation v Bendel, confirming the position for the taxpayer on Division 7A, unpaid present entitlements (UPEs), trust distributions, and private company loans. This is a landmark outcome for the taxpayer. The High Court has dismissed the Commissioner’s appeal, confirming that UPEs arising from […]

Simplify employee share scheme reporting with the CTS ESS Toolkit

28/05/2026

The Australian Taxation Office (ATO) has upcoming reporting obligations for entities offering an employee share scheme (ESS). Find out how the Complete Tax Solutions Employee Share Scheme (CTS ESS Toolkit), our ATO-approved software, can help you meet these requirements efficiently and accurately. Upcoming ATO reporting obligations The ATO requires employers that issue shares or share […]