Australia: Federal Court pauses Oracle royalty tax case to permit treaty arbitration with Ireland
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
See MoreAustralia: ATO updates private ruling guidance to address Pillar 2 matters
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
See MoreAustralia: ATO releases updated guidance on transitional CbC safe harbour rules for global and domestic minimum tax
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
See MoreAustralia, Ukraine sign income tax treaty
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
See MoreAustralia: Victoria government presents Omnibus state tax bill to parliament, seeks to refine existing frameworks for property taxes
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
See MoreAustralia: ATO updates monthly foreign exchange rates for the 2025–26 income year
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
See MoreAustralia: ATO releases updated excise tax guidelines for duty-free shops
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
See MoreAustralia: ATO releases updated excise tax guidelines for tobacco sector
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.
See MoreAustralia: ATO cautions of heavy penalties for global entities delaying TPAR submission
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
See MoreAustralia: ATO issues final guidance on guarantees and Division 7A avoidance
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
See MoreAustralia: Large companies continue to pay record levels of tax
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,
See MoreAustralia: ATO issues final ruling on thin capitalisation third-party debt rules
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
See MoreOECD: Australia, Belgium, Netherlands, New Zealand revise arbitration rules under BEPS MLI
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
See MoreAustralia: ATO releases summary of initial Pillar 2 briefing
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
See MoreAustralia: ATO issues final guideline on use of capital for funding franked dividends
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
See MoreAustralia: Government moves to cut ‘tax red tape’ to reduce regulatory, compliance burden for businesses
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
See MoreAustralia: ATO issues final guidance for the effective life of assets
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
See MoreUkraine: Cabinet of Ministers approves first income tax treaty with Australia
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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