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Chanel Palmer

Chanel is a Client Director in Pitcher Partners’ Tax Advisory Group, specialising in private wealth taxation, with particular expertise in Division 7A, trusts, managed funds, and engagement with Australian Taxation Office (ATO) reviews, audits and disputes. Before joining Pitcher Partners in 2020, Chanel held roles with both the ATO and Treasury across audit, technical and […]

Debt deduction creation rules now operative for many taxpayers

From 1 July 2024, the Debt Deduction Creation Rules (“DDCR”) permanently deny debt deductions (e.g. interest expenses) for payments arising in connection with certain related party transactions. Broadly, where entities have debt deductions that arise in relation to the acquisition of assets from associates, or fund distributions or royalties to associates, the rules will permanently […]

Our advocacy work: Draft PCG on restructures and the debt deduction creation rules

In April 2024, Australia’s new thin capitalisation rules become law. Broadly, thin capitalisation applies to entities part of multinational groups that incur debt deductions (e.g. interest) of more than $2 million for an income year (on a group basis). The legislation also introduced new integrity measures known as the debt deduction creation rules. The ATO […]

Compliance Committee Forum 2024

Pitcher Partners and Hall & Wilcox, together with the Melbourne Compliance Group, are delighted to bring to you the Independent compliance committee member forum webinar. Our panel of leading industry experts, led by Harry New of Hall & Wilcox provided updates on the recent developments and challenges facing financial services. Topics included: What fund managers need […]

Payroll tax issue of Uber payments to drivers decided

Key points The NSW Supreme Court initially ruled in favour of Uber, finding that payments to drivers were not wages and thus not subject to payroll tax under the contractor provisions. However, the NSW Court of Appeal later reversed this decision, concluding that payments made by Uber to drivers were ‘for or in relation to […]

Why and how to protect your SMSF against loss of a member’s capacity

Key points If an SMSF member loses mental capacity, the fund risks becoming non-compliant unless swift action is taken to remove them as trustee or director. Establishing an Enduring Power of Attorney (EPOA) for each SMSF member ensures continuity by allowing a trusted person to act on their behalf. Appointing a corporate trustee instead of […]

Snapshot of 2024-25 State & Territory Budget changes and other updates

With the exception of Tasmania, all Australian States and Territories have now delivered their Budgets for 2024-25. The first half of the 2024 calendar year has been a busy one in the world of State and Territory taxes, partly due to many measures associated with their budgets for 2024-25. The Budgets contain announcements regarding changes […]

Exposure Draft Legislation for Pillar Two

On 21 March 2024, draft legislation was released to implement the new Pillar 2 (or ‘GloBE’) rules (the Rules). The draft legislation will introduce a new tax regime and new compliance for multinational (MNE) groups that have an Australian presence and consolidated global revenue of Euro 750 million annually. The intention is to ensure that […]

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