Tim Frew

May 29, 2024 | mondaq.com | Adam Woodward |Chris Neil |Tim Frew

The Federal Budget has placed a strong emphasis on increasing support for housing development to address the current housing crisis by introducing over $6.2bn of new and additional spending on social and affordable housing, new housing infrastructure, and rent assistance, amongst others. From a tax perspective, however, the Federal Budget was very light on providing stimulus to increase investment in this area.

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.

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.

Mar 7, 2024 | mondaq.com | Sean R. Keegan |Neil Pereira |Patrick Graham |Tim Frew

This A&M Tax Brief summarises the current state of play for the new Australian thin cap rules, noting that the most recent amendments (circulated by the Government in November 2023) were approved by the senate committee and recommended to be passed as-is. The new rules are already in effect, although they have not been formally passed by parliament – that is, for taxpayers whose income years have commenced on or since 1 July 2023.