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 […]
The Federal Court in Morton v FCT [2025] FCA 366 (click here) allowed a taxpayer’s appeal against assessments that sought to tax on revenue account the gains made from the subdivision and sale of a family farm. Shortly after the farmland was zoned residential, the taxpayer engaged an external developer to undertake a project which […]
Legislation making the General Interest Charge (“GIC”) and Shortfall Interest Charge (“SIC”) non-deductible from 1 July 2025 has now passed both houses of Parliament and is set to impact taxpayers with tax liabilities that are overdue or arise due to tax shortfalls. Taxpayers should carefully consider the effects of the new measure. In particular, taxpayers […]
Key points The ATO’s Practical Compliance Guidelines 2021/4 will apply to all principals of certain professional firms starting in FY25. The Guidelines set out the risk of ATO audit or review activity in relation to the allocation of professional firm profits. Recent ATO communications highlight compliance issues in the legal profession. The Australian Tax Office’s guidelines relating to the […]
Peejade is a Client Director in the Tax Consulting division of Pitcher Partners Melbourne. With over 20 years of specialist experience in employment taxes, Peejade shares his expertise on both compliance and advisory matters. Prior to joining Pitcher Partners in 2023, Peejade was the national employment taxes leader for one of the largest corporates in […]
Chanel joined Pitcher Partners in 2020 as a Manager in the National Tax Group, working her way up to Client Director in 2025. Chanel has over 10 years of experience, and specialises in private wealth taxation, particularly Division 7A, trusts, corporate tax, managed funds and engagement with Australian Tax Office (ATO) reviews and disputes. Chanel […]
Elena is a Client Director in the Tax Consulting division of Pitcher Partners Melbourne. She has been advising in relation to employment taxes in a broad range of compliance and advisory matters. Prior to joining Pitcher Partners in 2015, Elena worked at a Big Four accounting firm obtaining extensive experience in the Employment Taxes and […]
Recent developments have confirmed the critical importance of trustees properly considering which beneficiaries should receive distributions and how those distribution entitlements are satisfied.
Recent court cases and ATO guidance products present additional challenges for trustees when considering how to distribute trust income.
An income tax generalist with over a decade of experience, Leo specialises in CGT, Trusts, Corporate Tax and Division 7A. He also sits on various committees including those with CA ANZ and the Tax Institute of Australia. Truly passionate about all things tax, he is constantly developing his deep expertise and keeping informed as to […]
Thank you for you interest