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Corporate and International Tax update

24/09/2025

Join our 2025 Corporate and International Tax update seminar to ensure you are up to date with the latest developments in corporate and international income tax. Our seminar will be delivered in an interactive hybrid format with SW Tax experts Daren Yeoh, Yang Shi and Kirsty McDonnell. Our speakers will equip you with invaluable insights […]

Federal Court of Australia rules annualised salary arrangements are not effective 

22/09/2025

The Federal Court of Australia, in a series of four cases involving Coles and Woolworths, ruled that both employers breached workplace laws by failing to correctly pay award entitlements to salaried managers.   The Court found that annual salaries cannot be used to offset overtime and penalties across pay periods, and that employers must meet award […]

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 […]

过渡时期澳大利亚的支柱二义务

26/08/2025

澳大利亚税务局（ATO）发布了新指南，帮助大型跨国公司履行支柱二税务规则规定的义务。虽然这些公司要处理的文件多了，还有可能面临处罚，但 ATO 会对过渡时期切实开展合规工作的企业宽大处理。    总览 实务合规指南草案 PCG 2025/D3 概述了 ATO 在过渡时期（2026 年 12 月 31 日或之前开始、2028 年 6 月 30 日或之前结束的财政年度）对申报义务和处罚的过渡性合规办法。 澳大利亚实施了 15% 的全球与国内最低税率（支柱二规则），这与支柱二项下的经合组织全球反税基侵蚀（GloBE）规则保持一致。其对象是受测年度之前的四个财政年度内至少有两个财政年度合并收入≥7.5 亿澳元的大型跨国企业（MNE）集团。支柱二规则自 2024 年 1 月 1 日起适用于澳大利亚。 值得注意的是，自 2025 年 1 月 1 日起，未征低税利润规则可能会使澳大利亚的跨国企业集团成员承担其他集团成员的相关补税。这与前者是否对后者拥有任何所有者权益无关。因此，审计人员可能要求对全球集团 2025 财年的情况开展支柱二分析。 澳大利亚的主要申报义务有哪些？ 适用的跨国企业集团必须提交以下材料： AIUTR、DMTR 和 FNF 被并入全球与国内统一最低报税表（CGDMTR）。GIR 仍是一项独立的义务。第一年的申报截止日期为财政年度结束后 18 个月，此后为 15 个月。对于以 2024 年 12 月 […]

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 […]

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 […]

Simplify employee share schemes reporting with the CTS ESS Toolkit

08/05/2025

The Australian Taxation Office (ATO) has upcoming reporting obligations for entities offering employee share schemes (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 who issue shares or share options […]

Late NFP self review return lodgement: ATO suspends penalties

15/04/2025

The ATO has introduced an annual self-review return requirement for non-charitable NFP organisations with an active Australian Business Number (ABN) to confirm their eligibility for income tax exemption. The inaugural NFP self-review return for the 2023–24 income year was due by 31 March 2025.  Please refer to our previous article for details on the questions […]