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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 […]

全中文税务与会计更新讲座 | Mandarin Tax and Accounting Update

26/04/2023

在我们近期的全中文财税更新讲座上，本所专家团队解读了近期主要财税变化，以及这些变化为企业与个人带来的影响与机遇。 At our recent Mandarin Tax and Accounting update, our team of experts discussed the recent key accounting and tax changes, the impact and opportunities that these changes would bring to individuals and businesses 税务与会计主题汇总 Summary of tax & accounting topics 税局新近动向 | Update on ATO activity   转让定价重大更新 | Major transfer pricing update 国际税收完整性措施更新 | Multinational tax […]

New thin capitalisation regime details released

23/03/2023

The Australian Treasury released Exposure Draft legislation aimed at strengthening Australia’s thin capitalisation (thin cap) rules. The Government is seeking feedback on the Exposure Draft which also proposes to disallow interest on debt used to fund foreign companies.   The Exposure Draft, released on 16 March 2023, is in line with the Government’s commitment to address […]

ATO updates Top 500 private groups tax program: how it affects your business

10/03/2023

The Australian Taxation Office (ATO) has updated its guidance on effective tax governance for the Top 500 private groups in Australia. The Top 500 program focuses on preventive action, and its key concept is ‘Justified Trust,’ which ensures confidence in the community that the largest private groups are paying the correct amount of tax. To […]

FBT record keeping relief for employers – ATO draft changes

01/03/2023

For employers lodging fringe benefits tax (FBT) returns, the volume of declarations and record keeping documentation is arduous and ongoing. Last week the Australia Taxation Office (ATO) issued four draft instruments that aim to reduce this. The draft legislative instruments specify acceptable alternative record-keeping obligations (other than an employee declarations) in respect of expense payment […]

Work from home – ATO revised deduction methods

22/02/2023

On 16 February 2023, the Australian Taxation Office (ATO) released a new guide, Practical Compliance Guide 2023/1 (PCG 2023/1), which revises the methods by which taxpayers can calculate deductions for costs incurred when working from home (WFH). One of the significant changes introduced by the ATO is the discontinuation of the 80 cents per hour […]

UGC releases Draft Regulations facilitating entry of foreign campuses in India

20/02/2023

The University Grants Commission (the “UGC”) has published the Draft Regulations that provide a framework for the establishment and operation of campuses of foreign higher educational institutions (FHEI) in India. Under the proposed regulations, foreign institutions may set up a campus in India independently to conduct undergraduate and higher-level degrees in India in all disciplines. […]

ATO targets Division 7A avoidance scheme

15/02/2023

On 8 February 2023, the ATO released a new Taxpayer Alert sounding a warning to taxpayers seeking to access private company profits tax free via a scheme involving the interposition of a holding company to access company profits tax free. The Taxpayer Alert notes that participants in, and promoters of these types of arrangements, may […]

Guardian case - tax appeal decision on section 100A – Trusts 

10/02/2023

On 24 January 2023, the Full Court of the Federal Court of Australia handed down its appeal decision in Commissioner of Taxation v Guardian AIT Pty Ltd ATF Australian Investment Trust [2023] FCAFC 3. The Court upheld the original judgement in favour of the taxpayer in relation to the application of section 100A but allowed the […]