IMF: Report Issued Following Consultations with Australia
On 18 January 2024 the IMF issued a report following discussions with Australia under Article IV of the IMF’s articles of agreement. The report noted that although Australia’s post-pandemic recovery was strong, tighter macroeconomic policies
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Australia: ATO plans draft taxation ruling on royalties
On 17 January 2024, the Australian Taxation Office (ATO) announced that it started consultation on a new Draft Taxation Ruling TR 2024/D1 Income tax: royalties - character of payments in respect of software and intellectual property rights. The new
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Australia: ATO Introduces new legislation to tackle Franking Credit distribution
On 6 December 2023, the Australian Taxation Office (ATO) announced the enactment of a new integrity rule to stop the distribution of franking credits funded by capital raising. The ATO has also initiated a public consultation concerning the
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Australia to halt deductions for ATO interest charges
On 13 December 2023, the Australian Taxation Office (ATO) announced that the government will amend the tax law to deny deductions for ATO interest charges as part of the 2023–24 Mid-Year Economic and Fiscal Outlook (MYEFO). This measure is not yet
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Australia: ATO wins case on diverted profits tax
The Australian Taxation Office (ATO) declared that a court has ruled in its favor for its decision about enforcing the diverted profits tax (DPT). The DPT applies to multinationals or significant global entities (SGEs) with an annual global income
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Australia: ATO announces GIC and SIC rates for Q3 2023-24
The Australian Taxation Office (ATO) has announced the general interest charge (GIC) rates and shortfall interest charge (SIC) rates for the third quarter of the 2023-24 income year. For the quarter commencing on 1 January 2024, the GIC annual
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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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