PwC's Monthly Tax Update Archive

December 2023

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• Final amendments to new thin capitalisation regime
• Operational Transfer Pricing – The new ‘cool kid’ on the block

November 2023

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• Amendments proposed to thin capitalisation reforms
• Implementation of Pillar Two in Australia
• What’s emerging: Payday Super consultation paper released 
• ATO guidance on Commissioner’s discretion regarding ‘control’: impact on R&D Tax Incentive claimants

October 2023

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• What’s trending: Payroll tax developments in the healthcare industry
• As ATO steps up vigilance and prepares for payday super, employers need smarter payroll governance
• International Tax News - September 2023
• NSW Budget 2023-24: Significant changes to the NSW duty base
• Federal Court deems frozen food products to be prepared meals subject to goods and services tax (GST)

September 2023

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• ATO finalises its views on deductibility of labour costs related to capital assets
• Australian Stamp Duty & Land Tax maps
• What’s emerging? Full Federal Court superannuation decision in employee/contractor matter appealed to the High Court
• What’s trending? Superannuation Guarantee obligations for workers in the entertainment or sports industry
• What’s trending? Federal Government, ATO double down on data-led superannuation reviews and debt-recovery proactivity

August 2023

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• ATO draft risk assessment framework for residency of foreign-incorporated companies
• OECD releases Pillar Two GloBE Rules Administrative Guidance and GloBE Information Return
• OECD releases Pillar Two STTR
• OECD Releases Pillar One Amount B
• What’s emerging? Deductibility of transport expenses: Federal Court decision qualifies approach from John Holland
• OECD releases Outcome Statement on the two-pillar solution

July 2023

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• Final taxation ruling: Residency tests for individuals
• Updated draft law on proposed intangibles integrity measure
• Legislation for multinational tax measures introduced into Parliament

June 2023

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• Draft ATO Guidance on cross border intangibles arrangements 

May 2023

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• Federal Budget Tax analysis and insights
• Doing business in Australia - multinational tax updates
• Proposed new country by country reporting
• United Kingdom releases draft pillar two legislation
• International tax news

April 2023

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• Employee share schemes: The ATO denies deduction for recharge payments
• Australia’s proposed intangible integrity measure
• Proposed new tax transparency measures for public companies
• Australia’s proposed new interest limitation regime
• Real assets and the new interest limitation rules
• Financial services and the new interest limitation rules
• Major changes to interest limitation rules in the Private Equity Sector
• Tax and ERP - Planning your tax function transformation

March 2023

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• What’s Emerging: ATO releases guidance on worker classification 
• Deep Dive: The FBT spectrum for electric car benefits
• OECD releases Pillar One Amount B consultation draft
• OECD releases Pillar Two guidance on Safe Harbours and Penalty Relief
• OECD announces Pillar Two GloBE information return consultation
• OECD announces Pillar Two tax certainty framework consultation
• PwC releases its 2022 Global Crypto Tax Report
• International tax news

February 2023

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• What’s Emerging: ATO releases guidance on worker classification 
  
• Deep Dive: The FBT spectrum for electric car benefits
• OECD releases Pillar One Amount B consultation draft
• OECD released Pillar Two guidance on Safe Harbours and Penalty Relief
• OECD announces Pillar Two GloBE information return consultation
• OECD announces Pillar Two tax certainty framework consultation
• PwC releases its 2022 Global Crypto Tax Report
• International Tax News

December 2022

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• The changing tax compliance landscape and connected processes and automation
• Draft law to change share buy-back tax rules for listed public companies
• Leases, Trusts and Options - Insights on NSW’s new “Change in Beneficial Ownership” Regime
• R&D Tax Incentive and Government grants landscape update
• What’s emerging? Electric Car FBT exemption awaiting Royal Assent
• Treasury consults on proposed public beneficial ownership register in Australia

November 2022

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• Federal Budget Tax analysis and insights

• ATO guide on market valuation for tax purposes

• ATO's latest findings from Top 1,000 reviews

• Draft Taxation Ruling TR 2022/D2 - ATO’s reinterpretation of individual tax residency rules

October 2022

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• Stapled structures, securitisation trusts and Part IVA

• What's emerging? Principles guiding the ATO's digital strategy and what it means for employer obligations

• What’s emerging? Proposed reduction to FBT record keeping compliance 

• OECD public consultation meeting: Amount A of Pillar One

September 2022

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• Deep Dive - Single Touch Payroll Phase 2: The importance of accurate payroll system mapping
• What’s emerging? Recent decision raises questions over the application of superannuation to annual leave loading 
• Reporting Regime for Online Marketplaces remains on Government agenda
• Consultation on Government’s multinational tax proposals
• Single Touch Payroll Phase 2: Communications and stakeholder management

August 2022

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• What’s emerging? Labor Government's electric car discount policy introduced

• Election Commitments Report reveals potential Australian changes to royalty and interest deductibility

• OECD releases a Progress Report on Amount A of Pillar One

• International Tax News

• Australian Stamp Duty and Land Tax Maps

July 2022

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• What’s emerging? Payroll tax: New law to deter non-compliance and avoidance in NSW

• OECD launches public consultation documents on Pillar One - Amount A: Tax Certainty

• GST Justified Trust and CAR 2.0

• EU Finance Ministers fail again to reach political agreement on proposed Pillar Two Directive

• US GILTI not a CFC rule for hybrid mismatches

June 2022

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• OECD launches public consultation document on Pillar One – Amount A: Regulated Financial Services Exclusion
• 2022-23 Northern Territory Budget
• 2022-23 Victorian State Budget
• OECD releases crypto-asset reporting framework and amendments to CRS
• OECD issues public consultation document on Pillar One - Amount A: Extractive Exclusion

May 2022

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• Funds management tax - Election special edition
• OECD launches public consultation on Pillar One draft Model Rules for domestic legislation on scope
• What’s emerging? Cost of Living Bill confirms deductibility of Covid-19 tests
• Treasury releases ‘FY23 Green Book’ describing President Biden’s tax proposals for businesses

April 2022

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• OECD releases Pillar Two Commentary and launches public consultation on the Implementation Framework
• Superannuation update: 2021 Federal Budget superannuation changes enacted or outstanding
• Australia’s new Alternative Investment Structure
  
• Federal Budget 2022-23 Tax Analysis and Insights
  
• Australian Stamp Duty Land Tax Maps March 2022
  

March 2022

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• Green Taxes and Incentives Tracker
• PwC Australia’s 25th CEO Survey
• What’s emerging? Contractor or Employee: High Court decisions mark directional shift in analysis
• What’s emerging? Concessional FBT for employer-provided Covid-19 testing

• ATO guidance on R&D “at risk rule” finalised
• India Budget 2022 - impact on foreign investors and multinationals

February 2022

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• Businesses that issue electronic invoices could have the right to require similar invoices from their trading partners
• ATO finalises Practical Compliance Guidelines on imported hybrid mismatches
• OECD releases Pillar Two 15% minimum effective tax rate Model Rules
• Global mobility policies and practices survey
• Why NSW’s proposed property tax reform is as safe as houses

December 2021

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• PwC Submission to Treasury - Supporting health and wellness through tax reform
• R&D tax offset - understanding affiliates and connected entities is key to getting your aggregated turnover calculation correct
• Increasing Climate Ambition: Analysis of an International Carbon Price Floor
• InTouch: Australia
• International Tax News

November 2021

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• Victorian Windfall Gains Tax and Build to Rent Amendments
• ATO releases Guide to Independent Data Testing by Third Party Advisors
• ATO’s decision impact statement on the Glencore transfer pricing case
• 130 countries agree on a new international corporate tax framework

October 2021

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• Corporate Collective Investment Vehicle – draft tax law released

• What's trending ? Wage trust remains a key Government and Regulator focus

• COVID-19: Support and assistance

September 2021

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• A simpler system for employee share schemes
• Updated ATO guidance dealing with residency and source of income for COVID-19 impacted mobile employees
• Dynamic changes proposed for Australia’s skilled migration program
• COVID-19: Support and assistance
• Reporting Regime for Online Marketplaces coming soon

August 2021

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• Sharing economy reporting regime for marketplaces coming soon
• RTP Schedules: The Who, What, When and Why

July 2021

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• ATO considers certain payments for software distribution rights are royalties
• Tap into Tax: Tax controversy - addressing risk in a world of increased tax scrutiny

June 2021

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• Federal Budget insights
• 2021-2022 Victorian State Budget
• Draft ATO guidance on cross-border intangible arrangements
• Client Insight: Update on ATO COVID measures on Permanent Establishments
• COVID-19 will force a major rethink of tax systems
• NSW wind farm held to be a fixture and valued under a profit rental approach - SPIC Pacific Hydro v Chief Commissioner of State Revenue

May 2021

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• ATO Practical Compliance Guidelines on imported hybrid mismatches
• Fringe benefits tax: New exemption to support retraining and reskilling
• Federal Budget Insights 2021-2022

April 2021

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• Superannuation guarantee: Rate increase and new super choice rules
• AmCham & PwC Australia Report
• This month in Payroll - March 2021

March 2021

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• Payroll tax: busting the myths and fixing the system
• ATO guidance on costs of travelling
• OECD releases guidance on the transfer pricing implications of COVID-19 - Australian considerations 
• This Month in Payroll: February 2021

February 2021

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• The road to economic recovery: Registrations are open for the JobMaker Hiring Credit- Learn more 
• NSW Jobs Plus Program - Applications now live - Read more 
• Proposed Industrial Relations reform at a glance - Details of the case 
  
• ATO’s final guidance on cross-border related party interest-free loans - Key highlights 
• Temporary full expensing of depreciating assets -What does this mean for you? 

December 2020

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• ATO loses transfer pricing appeal - The takeaways
• Tribunal finds administrators were not entitled to claim input tax credits on costs paid by administrators - Read more 
• Have you got the right evidence for your R&D claim? - Details of the case 
  
• NSW 2020-21 Budget announcements and proposed tax reform - Key highlights 
• The road to economic recovery: JobMaker Hiring Credit - Learn more 

November 2020

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• Federal Budget 2020-21 insights - tax measure to stimulate the economy
  
• Federal Budget boosts the benefit for R&D Tax Incentive claimants - how will it affect you?
• Aggregated turnover thresholds for loss carry-back and super-charged instant asset write-off measures
• Temporary loss carry-back rules - What you need to know

October 2020

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• Federal Budget insights - follow for the latest updates
• JobKeeper extension - everything you need to know
• Build to rent in Australia - continuing the conversation
• InTouch - quarterly developments in VAT and GST in APAC

September 2020

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• Further enhancements to JobKeeper
• The ATO recommences its ‘Next Actions’ compliance program
• ATO releases long awaited guidance on cross-border related party interest-free loans
• Finalised guidance on the arm’s length debt test from ATO

August 2020

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• How GST reform can help reboot prosperity for Australia
• Recent JobKeeper updates: what you need to know
• Capital vs revenue? Greig’s case confirms it's all about the facts
• ATO releases its GST Governance, Data Testing and Transaction Testing guide
• Queensland Foreign Land Tax Surcharge - Release of Ex Gratia Relief Guidelines

July 2020

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• InTouch: The latest indirect tax news for the Asia Pacific region
• This Month in Payroll – June edition
• Tax policy considerations in dealing with COVID-19 impacts

June 2020

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• Tax reform in the wake of COVID-19
• Reboot Australia: resetting Australia's economy after COVID-19
• Hybrid mismatch rules: proposed changes before parliament

May 2020

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• JobKeeper payments
• State Tax COVID-19 updates
• Guidance on tax obligations and relief for individuals affected by COVID-19
• COVID-19: tax issues for the Real Estate and Infrastructure sectors
• Guidance around deductions for work expenses

April 2020

As the international and domestic response to the spread of COVID-19 continues to develop, we know that organisations are facing significant challenges and need to respond rapidly. With this in mind, we have replaced the usual updates document with our tax-related COVID-19 website resources which are updated in real-time as the situation evolves.

Monthly features:

• How can the tax obligations of companies change from responses to COVID-19

• Immigration COVID-19 updates

• Instant asset write-off and accelerated depreciations deductions

March 2020

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• A year-end update on all things FBT

• The Superannuation Guarantee Amnesty

• The recent expansion of the definition of ‘significant global entity’

• “Tweaks” to the Australian hybrid mismatch rules

February 2020

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• The ATO continues its focus on crossborder arrangements involving intangible assets
• Will your Employee Share Trust meet the “sole activities” test under the ATO’s new guidance?
• Planes, trains and automobiles: new ATO draft ruling on work-related transport
• Draft ATO guidance for sovereign immunity and superannuation funds for foreign residents exemptions

December 2019

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• Queensland Payroll Tax - new compliance approach
• US Global Intangible Low-Taxed Income and hybrid mismatches
• Car parking fringe benefits' burden may increase under ATO's new draft views

November 2019

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• PwC's Worldwide Tax Summaries online tool
• Deductions for holding vacant land that may now be limited
• The removal of the main residence capital gains tax exemption for foreign residents

October 2019

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• Will your Employee Share Trust meet the "sole activities" test under the ATO's new guidance?
• Superannuation Guarantee Amnesty – It’s back, but will it be passed?
• A recent High Court decision resolves the meaning of “permanent place of abode”
• Federal Court overturns ATO positions on transfer pricing
• PCG 2019/D3 – A way forward on the Arm’s Length Debt Test

September 2019

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features:

• Tariff tensions between the US and China continue
• TP Talks: ATO PCG on inbound distribution arrangements
• Flexibility in Global Mobility: The gap between theory and practice

August 2019

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news. 

Monthly features

• Final guidance on applying STP to inbound employees on a shadow payroll
• India: 2019 budget - Impact on foreign investors and multinationals
• ATO continues to finalise views on cross-border debt issues
• PwC's Quarterly Tax Briefing Insights

July 2019

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features

• Australia and New Zealand approach to dual resident entities
• Work programme for reaching consensus on tax challenges from digitalisation sets ambitious targets according to stakeholders
  
• Tax Function of the Future series: Six Priorities for your Tax Agenda
• International Tax News

June 2019

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news. 

Monthly features

• Post-2019 Federal Election– Forward tax agenda
• No deduction for certain non-compliant payments for work and services
• GST ‘Division 129’ adjustments– have you decided to offer new residential stock for rent?
• The state of play in the Game of Trade

May 2019

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features

• Clarity for fund investors in complex RCF case
• ATO guidance on low tax lender rule
• TR 2019/D2 - An ATO refresher on the Arm’s Length Debt Test
• Small business tax concessions - ATO finalises guidance on carrying on a business

April 2019

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features

• Important year-end updates for Fringe Benefits Tax
• What you have 'GoT' to know about the trade war
• Commonwealth tenders – new satisfactory tax record requirements
• Token Raises - the next stage in the Cryptocurrency saga?
• Leave Loading and Superannuation Guarantee

March 2019

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features

• Commissioner of Taxation v BHP Billiton Limited: consideration of sufficient influence
• Similar Business Test - greater flexibility or continued uncertainty?
• Australia: Residency case a win for the taxpayer
• Creating value beyond the deal

February 2019

Recent updates in the areas of corporate tax, employment tax, international tax, indirect tax, state taxes, superannuation, legislative, and other news.

Monthly features

• Recent insights into ATO streamlined assurance reviews
• Goodwill: leaving its mark across duty and income tax legislation
• New lease accounting standard: Tax matters for lessees
• 2018-19 MYEFO: A few tweaks to tax measures
• ATO finalises controversial guideline on tax residency of foreign companies
• ATO revises simplified transfer pricing record keeping guidance