Federal Budget | The forward tax agenda

In this section of our 2025-26 Federal Budget tax analysis, we outline the forward agenda for personal and business tax and superannuation measures yet to be enacted.

Measures currently progressing

Measure	Status
Business and investment
Implement the Crypto Asset Reporting Framework (CARF) developed by the OECD for the collection of sharing of tax-related information on crypto asset transactions.	Consultation paper released on 21 November 2024 seeking views on how Australia should implement the CARF.
Extend the temporary increase to the instant asset write off threshold to $20,000 for small businesses for eligible assets first used or installed ready for use from 1 July 2024 through to 30 June 2025.	Amendments are currently proposed to be made to a Bill before Parliament to implement this proposal.
Exclude gambling and tobacco from the research and development (R&D) tax incentive.	Announced in the 2024-25 Mid Year Economic and Fiscal Outlook. No progress to date.
Introduce ‘Payday Super’ from 1 July 2026, which will align employer payment of superannuation guarantee entitlements with the payment of an employee’s salary or wages.	Draft legislation released for public consultation on 14 March 2025.
Clarify access to managed investment trust (MIT) concessions for widely-held investors.	Announced on 13 March 2025 following the release of Taxpayer Alert TA 2025/1. See Business and investment section for further information.
Extend the existing clean building MIT withholding tax concession (currently 10%) on certain fund payments so as to apply to data centres and waterhouses that meet energy efficiency standards.	Announced in the 2023-24 Federal Budget. No progress to date. The Government announced in this year’s Federal Budget that the start date of this measure would be deferred. See Business and investment section for further information.
Clarify the law to ensure tax deductions are available for interest payments on foreign bail-in bonds.	Announced in the 2024-25 Mid Year Economic and Fiscal Outlook. No progress to date.
International tax
Apply new penalty to large businesses undervaluing or mischaracterising royalties, dividends or interest.	Penalties relating to royalties announced in the 2024-25 Federal Budget, and penalties relating to dividends and interest announced in 2024-25 Mid Year Economic and Fiscal Outlook. No progress to date.
Strengthen the foreign resident capital gains tax (CGT) regime.	Consultation paper on this measure was released on 23 July 2024. The Government announced in this year’s Federal Budget that the start date of this measure would be deferred. See International tax and trade section for further information.
Expand Australia’s tax treaty network.	New treaty signed in 2023 with Portugal and in 2024 with Slovenia and others are progressing (e.g. Ukraine, Brazil, New Zealand and Sweden).
Personal tax
Reduce the tax concessions for individuals with a total superannuation balance above $3m by imposing an additional 15% tax on certain earnings from 1 July 2025.	Currently before Parliament.
Remove $2 minimum for tax deductible gifts.	Announced in the 2024-25 Mid Year Economic and Fiscal Outlook. No progress to date.
Other measures
Expand the application of the general anti-avoidance rules for income years commencing on or after the day the amending legislation receives Royal Assent.	Announced in the 2023-24 Federal Budget. No progress to date.
Amend tax scheme penalties to ensure they apply appropriately to taxpayers in a loss position.	Announced in the 2024-25 Mid Year Economic and Fiscal Outlook. No progress to date.
Deny deductions for general interest charge and shortfall interest charge.	Currently before Parliament in Treasury Laws Amendment (Tax Incentives and Integrity) Bill 2024.
Beneficial ownership registry to be introduced to improve transparency of corporate structures.	Draft legislation on enhanced beneficial ownership disclosures for listed entities released for public consultation on 14 November 2024. On 5 December 2024, Treasury released policy specifications in relation to beneficial ownership reforms for unlisted companies.

On 21 March 2025, the Government released the Board of Taxation’s report on the tax treatment of digital assets and transactions in Australia. The Board concluded that generally, the taxation of crypto assets and transactions can be accommodated by Australia’s current taxation law. In its response, the Government agreed that no specific tax legislation for digital assets and transactions should be introduced at the current time and agrees in principle with using the framework developed by the Board as a broad guide for assessing the suitability of any potential tax law amendments in relation to digital assets and transactions. It notes that Decentralised Autonomous Organisations (DAOs), Decentralised Finance (DeFi), Gaming Finance (GameFi), and Non-Fungible Tokens (NFTs) are areas that may benefit from further consideration as the market develops.

There are several tax measures announced by the former Government that are still outstanding with no indication of whether the current Government intends to proceed with them, including the previously announced changes to the tax residency rules for individuals and companies, and reforms to the Division 7A law relating to private company deemed dividends.