Australia: Government releases amended interest limitation rule
On 28 November 2023, the Australian government released the amendments and a supplementary explanatory memorandum to the interest limitation rules within the Treasury Laws Amendment (Making Multinationals Pay Their Fair Share—Integrity and
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Australia: ATO updates guidelines on central management and control test of residency
The Australian Taxation Office (ATO) has released updated guidelines that give foreign companies greater certainty about the compliance under the central management and control test. For better clarification to foreign companies regarding their
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Australia increases interest rate for simplified transfer pricing record-keeping options for loans
On 8 November 2023, the Australian Taxation Office (ATO) released an updated version of practice compliance guideline on simplified transfer pricing record-keeping options (PCG 2017/2). The updates outline the safe harbor interest rate for the
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Australia: ATO provides clarity on R&D tax incentive integrity rules
On 27 October 2023, the Australian Taxation Office (ATO) released a notice where it clarified the application of integrity rules for the R&D Tax Incentive. The identified issues with the application of some R&D program integrity rules
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Australia extends deadline for submitting CbC reports, Master file & Local file
The Australian Tax Office (ATO) has announced that taxpayers with country-by-country (CbC) reporting obligations for the year ending 31 December 2022 will now have until 31 January 2024 to submit their reports. This extension applies to the CbC
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Australia seeks feedback on amendments to interest limitation rules
On 18 October 2023, the Australian Treasury Department opened a consultation on an exposure draft bill to amend the interest limitation rules. As part of the 2022-23 Budget, an integrity measure was announced to address risks to Australia’s
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Australia: ATO encourages taxpayers to register for R&D tax incentive
The Australian Taxation Office (ATO) has reminded taxpayers about the importance of registering eligible R&D activities within 10 months from the end of the income year to claim the R&D Tax Incentive. To claim the R&D Tax Incentive
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Australia: ATO publishes SIC and GIC rates for October to December 2023
On 12 September 2023, the Australian Taxation Office (ATO) has published the shortfall interest charge (SIC) rates and general interest charge (GIC) rates for October – December 2023. How GIC is calculated Section 8AAD of the Taxation
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Australia: ATO consults on implementation of Global Minimum Tax rules
On 11 August 2023, the Australian Taxation Office (ATO) officially initiated targeted public consultation regarding the adoption of Pillar 2 global minimum tax rules. Consultation is being undertaken in a phased approach: Phase 1 with industry
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Australia conducting performance audit on TP management
The Australian National Audit Office (ANAO) is conducting a performance audit to evaluate the efficiency of the Australian Taxation Office's (ATO) transfer pricing (TP) management concerning loans between related parties. The ANAO proposes to
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Australia: New legislation proposes amendments to interest limitation rule
Legislation has been introduced in Parliament, suggesting amendment to the interest limitation or thin capitalization rules, which is closely align with the exposure draft legislation. If approved, these rules will be effective for income years
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Australia delays public CbC reporting implementation
On 23 June 2023, the Australian government declared that it has decided to delay the implementation of public country-by-country (CbC) reporting requirement to 1 July 2024 considering feedback from stakeholders. The focus of stakeholder feedback
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Australia: Federal Budget for FY 2023-24
On 9 May 2023, Mr. Jim Chalmers, the Australian Treasurer handed down Federal Budget for FY 2023-24, with some proposed changes to tax and superannuation laws. Many of the measures announced are subject to receiving royal assent and therefore not
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Australia declares small business energy incentive
The Australian Taxation Office (ATO) has declared small business energy incentive with an additional 20% deduction on eligible expenditures aimed at promoting electrification and enhancing energy efficiency. Eligible assets or upgrades will need
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Australia releases draft legislation on public CbC reporting requirement
On 6 April 2023, the Australian Treasury Department issued draft legislation outlining the implementation of public country-by-country (CbC) reporting requirements for specific tax-related information to be disclosed by multinational enterprises
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Australia declares R&D tax incentive application deadline
On 4 April 2023, the Australian Taxation Office (ATO) announced the deadline for companies to apply for the R&D Tax Incentive for financial year 2021-22. If a company operates on a standard income year (1 July to 30 June), the statutory
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Australia releases exposure draft bill on new thin cap rules
On 16 March 2023, the Australian Treasury issued the Exposure Draft on the earnings before interest, taxes, depreciation, and amortization interest limitation rules (EBITDA). Consultation closes on 13 April 2023. The proposal to change the
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Australia: ATO releases Reportable Tax Position Schedule 2023
On 10 Mar 2023, the Australian Taxation Office (ATO) has released the Reportable Tax Position (RTP) schedule for 2023. To determine whether a company needs to file an RTP schedule, they must conduct a self-assessment. Entities need to complete
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