Australia: Federal Court pauses Oracle royalty tax case to permit treaty arbitration with Ireland

28 October, 2025

The Full Federal Court of Australia ruled in favour of Oracle, allowing its Mutual Agreement Procedure with Ireland to proceed by staying domestic tax proceedings, reaffirming taxpayers’ treaty rights to prevent double taxation over intra-group

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Australia: ATO updates private ruling guidance to address Pillar 2 matters

24 October, 2025

The update introduces provisions enabling private rulings on Pillar Two interpretative issues and a new “decline to rule” mechanism, reflected in the addition of sections 40A and 40B. The Australian Taxation Office (ATO) has released an

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Australia: ATO releases updated guidance on transitional CbC safe harbour rules for global and domestic minimum tax

23 October, 2025

The updated guidance will help taxpayers determine whether the transitional CBC reporting safe harbour applies and how it may simplify their Pillar Two compliance obligations. The Australian Taxation Office (ATO) has released updated Global and

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Australia, Ukraine sign income tax treaty

20 October, 2025

The treaty establishes the first bilateral agreement between Australia and Ukraine and aims to eliminate double taxation on income, capital, fringe benefits, and withholding tax while preventing tax evasion or avoidance. Australia and Ukraine

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Australia: Victoria government presents Omnibus state tax bill to parliament, seeks to refine existing frameworks for property taxes

20 October, 2025

The bill proposed various changes, including adjustments to the Commercial and Industrial Property Tax Reform Act 2024, refining the criteria for transactions eligible under the commercial and industrial property tax scheme.  The Victorian

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Australia: ATO updates monthly foreign exchange rates for the 2025–26 income year

14 October, 2025

The ATO has updated its foreign exchange rate guidance, including monthly exchange rates for 1 July 2025 to 30 June 2026, which covers the rates for September 2025. The Australian Taxation Office (ATO) has updated its foreign exchange rate

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Australia: ATO releases updated excise tax guidelines for duty-free shops

10 October, 2025

The revised guidelines align with recent legislative reforms introduced to simplify and modernise the overall excise administration process. The Australian Taxation Office (ATO) has updated its excise tax guidelines for the duty-free shops. These

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Australia: ATO releases updated excise tax guidelines for tobacco sector

10 October, 2025

The revised guidelines align with recent legislative reforms introduced to simplify and modernise the overall excise administration process. The Australian Taxation Office (ATO) has updated its excise tax guidelines for the tobacco industry.

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Australia: ATO cautions of heavy penalties for global entities delaying TPAR submission

10 October, 2025

The ATO warns that Significant Global Entities (SGEs) that missed the 28 August TPAR deadline may face penalties for late lodgment. The Australian Taxation Office (ATO) announced on 8 October 2025 that Significant Global Entities (SGEs) may face

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Australia: ATO issues final guidance on guarantees and Division 7A avoidance

07 October, 2025

The guidance finalises ATO’s guidance and clarifies its view on the application of section 109U to private company arrangements involving guarantees under Division 7A. The Australian Taxation Office (ATO) announced it issued Taxation

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Australia: Large companies continue to pay record levels of tax

06 October, 2025

Corporate tax remains high as nil-tax entities decline. The Australian Taxation Office (ATO) has published its annual Corporate tax transparency (CTT) report revealing large corporates paid a combined AUD 95.7 billion in income tax in 2023–24,

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Australia: ATO issues final ruling on thin capitalisation third-party debt rules

06 October, 2025

The TPDT, introduced by the 2024 Treasury Laws Amendment, replaces the arm's length debt test for general investors and financial entities with a simpler, more streamlined method. The Australian Taxation Office (ATO) has issued Taxation Ruling TR

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OECD: Australia, Belgium, Netherlands, New Zealand revise arbitration rules under BEPS MLI

01 October, 2025

Part VI of the MLI enables jurisdictions that opt in to implement mandatory binding arbitration to resolve disputes arising under tax treaties. The OECD has released updated arbitration profiles for Australia, Belgium, Netherlands, and New

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Australia: ATO releases summary of initial Pillar 2 briefing

29 September, 2025

The session focused on the engagement with multinational enterprise (MNE) groups that may be in-scope of the measure, and with tax advisers providing specialist services around Pillar Two.  The Australian Taxation Office (ATO) has released a

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Australia: ATO issues final guideline on use of capital for funding franked dividends

27 September, 2025

The Guideline explains how the ATO assesses and applies compliance resources under section 207-159 of the ITAA 1997 to determine when franking credits on a distribution may be denied. The Australian Taxation Office (ATO) released Practical

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Australia: Government moves to cut ‘tax red tape’ to reduce regulatory, compliance burden for businesses

26 September, 2025

To simplify Australia’s tax system and boost economic productivity, the government has tasked the Board of Taxation with reviewing ways to cut red tape and reduce compliance burdens for businesses. Australia’s Treasurer Jim Chalmers announced

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Australia: ATO issues final guidance for the effective life of assets

25 September, 2025

The guidance helps determine how much of the asset’s cost taxpayers can claim as a tax deduction each year.  The Australian Taxation Office (ATO) has published the final guidance for the effective life of depreciating assets on 23 September

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Ukraine: Cabinet of Ministers approves first income tax treaty with Australia

24 September, 2025

This is the first ever income tax treaty between Ukraine and Australia.  Ukraine's Cabinet of Ministers approved the signing of an income tax treaty with Australia on 17 September 2025. The agreement will eliminate double taxation concerning

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