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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 […]

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 […]

Feedback on Treasury’s Giving Fund reforms

07/08/2025

Our submission to the Government’s consultation paper reflects feedback raised by trustees of affected Funds on the proposed increase to the minimum distribution rate. Based on our discussions, trustees are concerned that the change is inconsistent with their Funds’ objective of providing long-term charitable support. The Treasury has released a consultation paper ‘Giving fund reforms: […]

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 […]

Section 899: Not a Big Beautiful Tax

30/05/2025

On 22 May 2025, the United States (U.S.) House of Representatives passed section 899, a retaliatory and penalty tax targeting inbound investments to the U.S. by foreign entities from countries (including Australia) imposing ‘discriminatory taxes’ against U.S. entities. As part of the One Big Beautiful Bill Act (the Bill) passed by the U.S. House of […]

Proposed Division 296 legislation: A new tax on superannuation balances

28/05/2025

With the Federal Election now run and won, the Federal Labor Government will re-introduce its proposed legislation – Division 296 – Better targeted superannuation concessions. The legislation targets individuals with a Total Superannuation Balance (TSB) above $3 million held across all super funds regardless of accumulation or retirement phase. Under the previously proposed legislation that […]

CTS GST Analytical Tool

21/05/2025

Taxpayers who have received a GST assurance rating through the ATO’s Top 100 or Top 1,000 programs are now required to complete the GST Supplementary Schedule. There is also an increasing expectation for taxpayers to undertake the GST analytical tool (GAT) or similar reconciliation on an annual basis to understand the variances between their financial […]

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 […]