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Newsletters
Our newsletters are more than just updates; they are a blend of expert analysis, up-to-date information, and practical advice designed to guide you through the intricacies of taxation in Australia. Whether you’re a professional in the field, a business owner, or simply keen on staying informed, our archive is your go-to resource for valuable insights and informed perspectives. Browse, learn, and stay ahead in the dynamic world of Australian taxation.
May 2024 Newsletter
May 2024
Last week’s Federal Budget contains a proposal for a new measure from 1 July 2026 that applies a penalty to taxpayers who are part of a group with more than $1 billion in global turnover annually that are found to have mischaracterised or undervalued royalty payments, to which royalty withholding tax would otherwise apply. There are obviously significant details to be fleshed out, such as the interaction with Part IVA, DPT and our treaties. Together with details on how they will be “found” to have made the “mischaracterisations” or “undervaluations”.
But the proposal certainly brings into sharp focus the appeal in PepsiCo in the Full Federal Court, heard a week ago. Today’s newsletter discusses the three day hearing and some of the the arguments about the drafting and structure of the agreements that were put to the Court there.
I welcome your thoughts! Let me know if you would like to discuss.
Kind regards,
Paul.
January 2024 Newsletter
Jan 2024
Happy 2024! In my first newsletter of the year I skim through a list of some of the Federal Court cases we expect to see developments on this year, together with legislation which is already in progress and announcements which have already passed their commencement date but where we have not already seen draft legislation. I also touch on some ATO guidance which is underdevelopment and due out shortly!
All are interesting, and I would love to hear your thoughts on them. Let me know if you would like to discuss any of them.
Kind regards,
Paul.