Key points The High Court found payments for concentrate were not royalties paid to PepsiCo Payments were for concentrate only, not for intellectual property use. Diverted Profits Tax did not apply, as no reasonable alternative arrangement existed. In doing so, the High Court accepted a “do nothing” scenario (that the taxpayer would never have entered […]
With over 16 years of experience at Pitcher Partners Melbourne, Angela Bryce is a Client Director in the Tax Advisory Group. Since starting her career in 2008, Angela has advised a wide range of clients including listed public companies, large corporates, high wealth individuals and family groups. Specialising in both International Tax and Employment Taxes, […]
Update July 14, 2025 The US “One Big Beautiful Bill”, which proposed sweeping international tax reforms including retaliatory tax increases on foreign income, has now passed through Congress. Initially flagged as a concern for Australian taxpayers with US-sourced income, the final version has removed Section 899 following negotiations with the G7, meaning most of the […]
Key points Remote work is becoming a permanent fixture in the global workforce, with employees demanding more freedom and flexibility Employers of Record (EOR) help businesses manage international work arrangements by handling payroll, benefits, and compliance with local laws Using EORs comes with challenges and risks, such as potential tax and legal implications, requiring robust […]
The ATO has announced changes to disclosure requirements and reporting obligations with particular focus on high-risk transactions (intercompany financing and intangibles) plus expanded definitions of business restructures which will significantly increase the compliance burden for large multinational enterprises with Australian tax reporting obligations. Please see below a summary of the most relevant developments. New local […]
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 […]
In April 2024, Australia’s new thin capitalisation rules become law (see here). 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. […]
Our cross-border tax experts Terry Hoban and Ellen Fimmano discuss some of the practical challenges and important considerations that arise for organisations, their employees, and owners expanding into the USA, including: Cross-border entity structuring & tax considerations Employee payroll & HR set-up Equity plans, pensions, and employee benefits Individual tax planning for Australian executives relocating […]
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