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 […]
In June 2023, legislation containing new thin capitalisation rules from 1 July 2023 was introduced into Parliament.
After first being released as exposure draft legislation in March 2023, the new thin capitalisation interest limitation rules have undergone several round of updates but are still not law.
In response to an increased global focus on corporate transparency and exchange of information, effective 1 January of 2024 US businesses are now required to provide beneficial ownership information (BOI) to the US treasury department, via the Financial Crimes Enforcement Network (FinCEN).
Recently, Pitcher Partners Sydney hosted a webinar addressing key tax considerations for individuals with UK and Australian ties.
Treasury is consulting on a new individual tax residency framework that is based on recommendations made by the Board of Taxation in 2019.
Legislation has been introduced into Parliament that significantly rewrites Australia’s thin capitalisation rules with effect from 1 July 2023, with no grandfathering or transitional relief.
In June 2023, legislation containing new thin capitalisation rules from 1 July 2023 was introduced into Parliament. 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).
In April 2023, the Government released exposure draft legislation for public comment seeking to introduce public country-by-country reporting obligations for income years commencing on or after 1 July 2023 for multinational groups with a tax presence in Australia.
In April 2023, the Government released exposure draft legislation for public comment seeking to introduce a new measure to deny deduction for payments for the exploitation of intangible assets that are made by significant global entities to associates in foreign jurisdictions with a corporate tax rate of 15% or less.
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