From 1 July 2024, the Debt Deduction Creation Rules (“DDCR”) permanently deny debt deductions (e.g. interest expenses) for payments arising in connection with certain related party transactions. Broadly, where entities have debt deductions that arise in relation to the acquisition of assets from associates, or fund distributions or royalties to associates, the rules will permanently […]
In April 2024, Australia’s new thin capitalisation rules become law (see here). Broadly, thin capitalisation applies to entities part of multinational groups that incur debt deductions (e.g. interest) of more than $2 million for an income year (on a group basis). The legislation also introduced new integrity measures known as the debt deduction creation rules. […]
Pitcher Partners and Hall & Wilcox, together with the Melbourne Compliance Group, are delighted to bring to you the Independent compliance committee member forum webinar. Our panel of leading industry experts, led by Harry New of Hall & Wilcox provided updates on the recent developments and challenges facing financial services. Topics included: What fund managers need […]
This article first appeared in TaxVine, a members newsletter from The Tax Institute. On 6 September 2024, the New South Wales Supreme Court delivered its decision in Uber Australia Pty Ltd v Chief Commissioner of State Revenue [2024] NSWSC 1124 (Uber). The Court considered whether Uber’s payments to drivers were subject to payroll tax, ultimately deciding in […]
With the exception of Tasmania, all Australian States and Territories have now delivered their Budgets for 2024-25. The first half of the 2024 calendar year has been a busy one in the world of State and Territory taxes, partly due to many measures associated with their budgets for 2024-25. The Budgets contain announcements regarding changes […]
On 21 March 2024, draft legislation was released to implement the new Pillar 2 (or ‘GloBE’) rules (the Rules). The draft legislation will introduce a new tax regime and new compliance for multinational (MNE) groups that have an Australian presence and consolidated global revenue of Euro 750 million annually. The intention is to ensure that […]
The NSW State Labor Government has admitted “the 2024-25 Budget projects a deficit of $3.6 billion in 2024-25, down from the $0.5 billion surplus projected in the 2023-24 Half-Yearly Review”. So, what does the State Budget offer to the NSW business community? From a State Tax revenue exercise, foreigners have been asked to pay more […]
As we near the end of the financial year, responsible entities, trustees and fund managers must prioritise tax compliance and investor reporting. Failing to address key issues could lead to unexpected tax liabilities for trustees or significant taxable income for members without sufficient cash distributions. 1. Setting a timetable Where your fund has made distributions […]
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