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支柱二常见问答：关于全球最低税的重要见解

26/03/2025

支柱二实施了一套全球最低税框架，旨在确保跨国企业按公平原则纳税，不论其经营所在地。 本常见问答栏目针对支柱二的实施、对企业的影响以及合规要求这几方面的重要问题提出了看法。无论贵公司想了解实际税率、报告义务还是豁免，都可以在此找到清楚扼要的答案。

AASB 18: Key changes in presentation of profit & loss of listed entities

31/10/2024

The introduction of a new accounting standard, AASB 18, represents a major change for financial reporting, particularly in the profit and loss statement for listed companies and Tier 1 reporters. AASB 18 Presentation and Disclosure in Financial Statements has been introduced to enhance the presentation of financial statement as well as for transparency and comparability […]

ATO appeals to High Court after reversal of PepsiCo decision 

30/08/2024

The ATO has sought special leave to appeal to the High Court, following the decision in Full Federal Court (by a 2 – 1 majority) in PepsiCo, Inc v Commissioner of Taxation [2024] FCAFC 86, which overturned the single decision that ruled in favour of the Commissioner’s position.   The High Court decision when released, is significant […]

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 […]

More thin capitalisation reforms - changes to Bill released

07/12/2023

The further thin capital amendments are a step in the right direction for significant multinational tax reform. However, more still needs to be done to ensure the Bill is a targeted and measured response to the issue of base erosion.  The government has introduced more amendments to the thin capitalisation and debt deduction creation rules […]

OECD Pillar Two GloBE rules – Global and domestic minimum tax seminar

24/10/2023

Our 2023 OECD Pillar Two GloBE rules – Global and domestic minimum tax seminar provided an update of the new requirements impacting multinational groups. Our online seminar was delivered in an interactive format with SW expert Daren Yeoh, Partner and Corporate & International Tax Director. This seminar covered the following topics: SW Speaker Daren YeohPartner […]

Bill for new thin capitalisation regime introduced

26/06/2023

Following consultation to the Exposure Draft legislation earlier this year, the Government has now introduced the Treasury Laws Amendment (Making Multinationals Pay Their Fair Share – Integrity and Transparency) Bill 2023 (the Bill) which details significant reforms to the thin capitalisation regime. Introduced into Parliament on 22 June 2023, the Bill is in line with […]

Major international tax reform with OECD Two-Pillar approach

10/05/2023

With increased globalisation and digitalisation creating growing concern about tax avoidance by multinationals, the OECD Two-Pillar approach aims to address international corporate tax challenges. In the 2023-24 Budget, the Government announced the implementation of a 15 per cent global minimum tax and domestic minimum tax, key aspects of Pillar Two of the OECD/G20 Two-Pillar Solution […]

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 […]

Property funds to be impacted by proposed thin cap changes

26/04/2023

The Government has released draft thin capitalisation law changes proposed to commence from 1 July 2023. If enacted, this may have a substantial impact on some property funds.  We recommend that all fund managers review their funds’ existing financing arrangements immediately to understand how the proposed rules impact interest deductions. For further details of the […]