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What the ATO’s finalised software royalties ruling & draft guidance means for businesses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

Pillar Two in year 2 & what's different from year 1

08/09/2026

For many multinational enterprise (MNE) groups, the first year of Pillar Two compliance (typically the year ended 31 December 2024) was largely a transition exercise. While most MNE groups spent considerable time understanding the rules, establishing governance processes, and assessing the availability of the Transitional CbCR Safe Harbour (TCSH), the practical compliance burden was often […]