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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 […]

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 […]

Darren O’Malley, Consulting Director

13/02/2025

Darren is a highly experienced taxation specialist with over 35 years; in the accounting industry, providing expert tax advice to businesses of all sizes. As a Master of Tax, he delivers high-level strategic tax guidance, ensuring optimal outcomes for clients. He has extensive experience in international tax matters, helping clients navigate complex global tax structures […]

Revised draft for Australian public country-by-country reporting

27/02/2024

Recently, the Treasury released a revised exposure draft (ED) proposing to require certain large multinational enterprises to publicly report selected tax information on a country-by-country basis effective on or after 1 July 2024. On 12 February 2024, the Treasury released the revised exposure draft (ED) and explanatory materials (EM), collectively referred to as ‘Revised Draft […]

Transfer pricing landscape and challenges | India & Australia perspective

19/09/2023

In today’s rapidly evolving business landscape, we are witnessing a significant shift in the dynamics of conducting business. The uncertainties surrounding established supply chains have prompted many countries to explore alternative business locations and trading partners. India and Australia have been two popular geographical choices of cross-border business investments, with investment opportunities re-growing during the […]

Australian Treasury denies SGEs deductions for payment relating to intangibles

05/05/2023

Exposure Draft Bill released by Australian Treasury denying SGEs deductions for payments attributed to intangible assets in low tax jurisdictions. The Exposure Draft Bill (the draft Bill), released on 31 March 2023, proposes a new anti-avoidance rule to deny deductions for payments attributed to intangible assets located in low corporate tax jurisdictions. Significantly, the changes […]

Ampol settles ATO tax dispute over offshore procurement hub: Key takeaways for transfer pricing compliance

07/03/2023

Ampol Limited, formerly Caltex Australia, has settled a transfer pricing dispute with the Australian Taxation Office (ATO) for $157 million. Ampol Group (Ampol) is an Australian energy company that operates in the fuel and convenience retail sector. Its subsidiaries in Singapore (Ampol Singapore) serve as a trading and shipping arm of the group, sourcing refined […]

International Mining and Resources Conference 2022

27/10/2022

For the first time in over three years, the International Mining and Resources Conference (IMARC) is welcoming attendees in person – this year, in Sydney. SW is proud to be part of the conversation at IMARC for the fifth time, taking the lead on sustainable and equitable futures by sponsoring the Investment Theatre. With a […]

Yang Shi, Partner

30/06/2022

Yang is a leader in SW’s national transfer pricing services, with over 17 years’ specialist experience in assisting multinational enterprises with their transfer pricing compliance and advisory. Fluent in English and Mandarin, Yang spent 9 years working at Big 4 firms in both China (Shanghai) and Australia (Perth and Melbourne). During his career, Yang was […]

Business advisory

17/02/2022

Our experienced team work closely with business owners, management teams, directors and boards to provide practical support for your growth and success. Sustaining or expanding a successful business requires a relationship with a trusted advisor. In real terms, we know that you want someone that you can have the challenging conversations with in relation to […]