Tax insights

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ATO published draft practical guidance on arm's length debt test - 29 August 2019

On 28 August 2019, the ATO released a draft Practical Compliance Guideline on its risk assessment framework and compliance approach on the application of the arm’s length debt test (ALDT) for thin capitalisation purposes. The PCG is intended to have effect from 1 July 2019 and will apply where the ALDT has been used to establish an entity’s maximum allowable debt from this date.

Recent Tax insights

New tax whistleblower regime - 27 August 2019

On 1 July 2019, the tax and general whistleblower provisions of Treasury Laws Amendment (Enhancing Whistleblower Protections) Act 2019 became operative. This Act streamlined the whistleblower regime within the Corporations Act 2001, and established a new tax whistleblower regime in Australia.

Reportable tax position regime extended to private companies - 1 August 2019

The Australian Taxation Office has released a consultation document on expanding the Reportable Tax Position regime to large private companies and corporate groups for income years ending on or after 30 June 2020.

It’s time to start considering how the application of the RTP regime will affect you and how you will prepare.

ATO rules that transfer pricing provisions override debt-equity rules - 24 July 2019

The ATO issued Taxation Determination TD 2019/10 on 3 July 2019, which deals with the interaction of the transfer pricing rules and the debt / equity rules.

The ATO’s view is that the debt / equity rules cannot limit the operation of the transfer pricing rules for related party financing transactions. The ATO view is that the debt/equity rules apply to classify the interest that arises by reference to the arm’s length conditions which are identified, not to the actual conditions.

The ATO’s expectations to obtain assurance – 16 July 2019

The Australian Taxation Office has recently shared the Top 1,000 Tax Performance Program (Income tax) Findings Report which highlights their key findings from over 280 streamlined assurance reviews conducted to March 2019 on large public and multinational taxpayers, as part of the Justified Trust program.

Personal tax cuts pass Parliament - 10 July 2019

On 5 July 2019, the Treasury Laws Amendment (Tax Relief So Working Australians Keep More of Their Money) Act 2019 was given Royal Assent.

This passed into law all three stages of personal tax cuts, which the Coalition Government announced in the 2019-20 Federal Budget and follows significant tax cuts announced and legislated in the previous term of Parliament.

Changes for tenderers & contractors to Commonwealth Government contracts - 12 June 2019

To address black economy concerns and enhance supply chain integrity, businesses tendering to the Federal Government must meet new procurement guidelines from 1 July 2019, including obtaining a Statement of Tax Record.

Update on OECD work on the tax challenges of digitalisation - 05 June 2019

As part of the ongoing work of the G20/OECD on Base Erosion and Profit Shifting, the OECD has recently released the Program of Work to Develop a Consensus Solution to the Tax Challenges Arising from the Digitalization of the Economy.

Deloitte's 2019 BEPS survey: an Australian perspective - 03 June 2019

Deloitte has recently published the results of its annual multinational survey regarding OECD’s Base Erosion and Profit Shifting (BEPS) initiative and the “Global Tax Reset.” Now in its sixth year, this survey identifies respondents’ views on the changing tax landscape, as well as the topics that were high on the agenda in 2018, such as the Multilateral Instrument (MLI), US Tax Reform and the ‘digital taxation’ debate.

Archive

Explore the archive of Tax insights below. If you cannot find the Tax insight you are looking for or if you would like more information on particular topic please contact us on taxinsights@deloitte.com.au.

2019

May 2019 | Understanding the ‘general purpose financial statements’ requirements for significant global entities – May 2019

20 May 2019 | Coalition Government returned: tax agenda

16 April 2019 | Understanding the post-election tax policies affecting business

16 April 2019 | Understanding the post-election tax policies affecting individuals

16 April 2019 | The latest from Canberra

03 April 2019 | Federal Budget 2019-20

15 April 2019 | ATO publishes “in-part” guidance on Arm’s Length Debt Test

11 April 2019 | Australia and Israel: double tax treaty

09 April 2019 | RCF: Certainty restored, and some more questions

27 March 2019 | Multilateral Instrument: now in force in Australia

26 March 2019 | ATO guidance on inbound distributors

19 March 2019 | Tax Transparency Code: proposed increase in scope

20 February 2019 | Tax challenges of digitalisation: OECD paper released

2018

2 September 2019 (Updated) | Black economy measures draw a wide net

26 October 2018 | Changes to the taxation of stapled structures and limitation of concessions for foreign investors

18 October 2018 | ATO releases revised guidance on MAP – what does it mean for you?

27 September 2018 | Diverted profits tax: where are we now?

25 September 2018 | Can you identify your Reportable Tax Positions?

25 September 2018 | R&D Tax Incentive Bill introduced into Parliament

August 2018 | More headaches for more Significant Global Entities

17 July 2018 | OECD releases Discussion Draft on the transfer pricing of financial transactions: An Australian perspective

25 June 2018 | Hybrid Mismatch and Multinational Group Financing Integrity Rules

21 June 2018 | Corporate residency test – ATO’s new approach

14 June 2018 | Senate Inquiry into corporate tax avoidance final report

20 February 2018 | GST withholding obligation for residential property purchasers

14 February 2018 | Resource Capital Fund decision

13 February 2018 | Foreign residents to be excluded from CGT main residence exemption

2017

20 December 2017 | ATO issues final compliance approach for cross borderrelated party debt funding

22 November 2017 | US Tax reform – What does it mean for Australia?

October 2017 | Clarity in financial reporting

7 September 2017 | Your tax affairs in the public spotlight

23 March 2017 | Selling low value goods to consumers in Australia – will you be GST ready?

2016

27th October 2016 | General purpose financial statements: the current state of play

2015

14th December 2015 | Foreign resident CGT withholding regime

4th November 2015 | Deconstructing the Chevron Transfer Pricing Case

18th August 2015 | The Senate Inquiry Interim Report