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. […]
Our cross-border tax experts Terry Hoban and Ellen Fimmano discuss some of the practical challenges and important considerations that arise for organisations, their employees, and owners expanding into the USA, including: Cross-border entity structuring & tax considerations Employee payroll & HR set-up Equity plans, pensions, and employee benefits Individual tax planning for Australian executives relocating […]
The Pillar Two rules will impose a minimum tax rate of 15% on multinational groups in the jurisdictions in which they operate. To achieve this, the rules are introducing three new tax returns and increasing transparency as they seek to raise the stakes of multinational group compliance. In this webinar, Pitcher Partners Sydney Elizabeth Jools […]
Pitcher Partners Sydney hosted a live webinar that helped attendees understand the key proposed tax changes likely to affect individuals and families with ties to both the UK and Australia. This webinar addressed whether the new changes would require attendees to plan differently for possible inheritance tax exposure. More specifically, our speaker Private Business and […]
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 […]
In June 2023, legislation containing new thin capitalisation rules from 1 July 2023 was introduced into Parliament.
After first being released as exposure draft legislation in March 2023, the new thin capitalisation interest limitation rules have undergone several round of updates but are still not law.
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