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Oct 11, 2024 | 
mondaq.com | Neil Pereira |Andrew Moore |Nick Moore
The Australian Taxation Office (ATO) is in the process of
finalising substantial modifications to the Australian local file
(ALF), particularly the short form local file (SFLF), for reporting
periods beginning on or after 1 Jan. 2024. These changes, set to
impact country-by-country (CbC) reporting entities, represent a
significant shift in reporting requirements and compliance
obligations.
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Aug 14, 2024 | 
mondaq.com | Neil Pereira |Joanna M. Black |Nick Moore
As expected, the Commissioner of Taxation
(Commissioner) has now applied for special leave
to appeal to the High Court of Australia in respect of the recent
decision of the Full Federal Court (FFC) in
PepsiCo, Inc v Commissioner of Taxation [2024] FCAFC 86
1.
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Jun 24, 2024 | 
mondaq.com | Neil Pereira |Nick Moore |Erica Birchall
Significant changes to Australia's corporate reporting rules
aimed at increasing transparency of the tax practices of
multinational companies are about to take effect.
The Treasury Laws Amendment (Making Multinationals Pay Their
Fair Share – Integrity and Transparency) Act 2024, received
Royal Assent on April 8, 2024, introducing a requirement for all
public companies to include a "consolidated entity disclosure
statement" in their annual financial reports.
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May 8, 2024 | 
mondaq.com | Neil Pereira |Andrew Sharp |Joanna M. Black |Amanda Spinks
Please join us in recapping this virtual event where we
presented a review of the latest tax developments in Australia
including legislative updates on thin capitalisation and Pillar 2,
recent case updates, public CBC, employment taxes and FBT.
Originally published 30 April 2024
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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Apr 23, 2024 | 
mondaq.com | Neil Pereira |Andrew Moore |Tim Frew
The Australian Taxation Office released the new 2024 Reportable Tax Positions (RTP) Schedule
last week and, as we indicated in our previous article here, there are new questions within the RTP
that continue the ATO's focus on intangibles migration and
Australian development, enhancement, maintenance, protection and
exploitation (DEMPE) activities per Practical Compliance Guideline
PCG 2024/1, highlighting transfer pricing and anti-avoidance
considerations in particular.
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Apr 22, 2024 | 
mondaq.com | Neil Pereira |Tim Edwards |Tim Frew |Chris Neil
The Full Federal Court has dismissed an appeal by Singapore
Telecom Australia Investments Pty Ltd (STAI) against transfer
pricing assessments issued by the Australian Taxation Office (ATO)
in relation to interest deductions claimed on related party
debt.
By reconstructing the reliable hypothetical transaction to be
on independent vendor financing terms, including an implied SingTel
parent guarantee, the Court concluded STAI received transfer
pricing benefits in the income years under review.
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Apr 16, 2024 | 
mondaq.com | Neil Pereira |Chris Neil |Tim Edwards |Edward Consett
In Minerva Financial Group Pty Ltd v Commissioner of
Taxation [2024] FCAFC 281, the Full Federal Court
reversed the Federal Court's decision in finding that
Australia's general anti-avoidance rules (Part IVA) did not
apply to income distributions made by a trust within a stapled
group structure. This article analyses the Full Federal Court's
reasons for their judgment, highlighting the emphasis placed on the
commercial substance over mere tax outcomes obtained.
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Mar 26, 2024 | 
mondaq.com | Neil Pereira |Sean R. Keegan |Andrew Moore |Chris Neil
In this article, we provide an overview of the OECD Pillar 2
framework and the current status of the rules in Australia, and
discuss some of the key implications and challenges for Australian
taxpayers and tax practitioners.
The Organisation for Economic Co-operation and Development
(OECD) has developed a two-pillar solution to address the tax
challenges arising from the digitalisation and globalisation of the
economy.
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Mar 26, 2024 | mondaq.com | Neil Pereira |Sean R. Keegan |Andrew Moore |Chris Neil
In this article, we provide an overview of the OECD Pillar 2
framework and the current status of the rules in Australia, and
discuss some of the key implications and challenges for Australian
taxpayers and tax practitioners.
The Organisation for Economic Co-operation and Development
(OECD) has developed a two-pillar solution to address the tax
challenges arising from the digitalisation and globalisation of the
economy.
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Mar 15, 2024 | 
mondaq.com | Neil Pereira |Jeff Wong |Chris Neil |Andrew Sharp
Background
AusNet Services was a stapled group consisting of AusNet
Services (Transmission) Limited, AusNet Services Finance (Finance)
Trust and AusNet Services (Distribution) Limited.
Each unit in Finance was linked to a share in Transmission and a
share in Distribution, such that none could be transferred or
otherwise dealt with without the others.
The stapled securities were listed on the Australian and
Singapore stock exchanges.
The full case transcript is available
here.
