Insights

ATO Draft PCG 2025/D2 – A new era of cross-border debt compliance

A new era of thin capitalisation rules. On 29 May 2025, the Australian Taxation Office (ATO) released Draft PCG 2025/D2 - a practical compliance guideline that reshapes how inbound, cross-border related-party financing arrangements are assessed under Australia’s thin capitalisation and transfer pricing rules.

Becky Nguyen

Partner

Melbourne

Insights

澳洲税务局草拟发布 PCG 2024/D3：跨国企业如何应对资本结构重组下的新合规挑战？

2024年12月，澳大利亚税务局（ATO）发布了《草拟实务合规指南 PCG 2024/D3》，明确了其对企业在新资本弱化规则（thin capitalisation）下进行融资重组时的合规处理立场。本篇文章深入解析三项关键内容：第三方债务测试（Third Party Debt Test）、债务利息扣除否决规则（Debt Deduction Creation Rules），以及为满足这些规则所进行的重组安排的合规指引，为跨国企业提供更具实操性的应对建议。

2 contributors

Melbourne

Insights

Essential insights for Multinational Enterprises

In December 2024, the ATO introduced Draft Practical Compliance Guideline PCG 2024/D3, which outlines the compliance approach for restructures of financing arrangements under the new thin capitalisation and debt deduction creation rules. This article explores the workings of these rules and their implications for MNEs' intercompany dealings. Third Party Debt...

Becky Nguyen

Partner

Melbourne

Insights

ATO overhauls local file reporting: key changes explained

On 23 December 2024, the Australian Taxation Office (ATO) introduced a new local file schema and finalised instructions for reporting periods beginning on or after 1 January 2024, marking significant changes for the 2025 income year. What's new? The ATO's new local file schema aims to gather more detailed and...

Becky Nguyen

Partner

Melbourne

Insights

The ATO’s Top 1000 CAR Program: an insight into transfer pricing assurance

The Australian Taxation Office (ATO) recently released its sixth findings report, providing key insights into its Top 1000 Combined Assurance Review (CAR) program, particularly focusing on transfer pricing and related areas. Introduced in 2020, the CAR program targets the top 1,000 Australian taxpayers to ensure compliance with taxation laws across...

Becky Nguyen

Partner

Melbourne

Insights

PKF worldwide tax updates — Australia

The latest edition of the PKF Worldwide Tax Update newsletter is now available. This issue highlights significant tax changes and amendments from around the globe, with each topic complemented by expert insights from PKF tax advisors. PKF Australia's contribution to this newsletter was authored by Becky Nguyen from PKF Melbourne....

Becky Nguyen

Partner

Melbourne

Insights

澳大利亚税务局Top 1000综合税务合规审查计划：跨国企业如何应对日益严格的税务审查？

随着全球税务透明度的提高以及各国税务机关对跨境交易的监管日趋严格，跨国企业正面临前所未有的合规挑战。

2 contributors

Melbourne

Insights

Pillar Two implementation in Australia: current state of play

On 22 August 2024, the Australian House of Representatives passed a new law that introduces a 15% global minimum tax and a domestic minimum tax for large multinational companies with yearly global revenues over €750 million. This move follows the Australian Government's 2023-2024 Budget plan, which included adopting the OECD/G20...

Becky Nguyen

Partner

Melbourne

Insights

Thin Capitalisation reforms and their impact on corporate tax management

As of 8 April 2024, the Treasury Laws Amendment (Making Multinationals Pay Their Fair Share - Integrity and Transparency) Act 2024 has officially been enacted. This landmark legislation introduces major reforms to Australia’s Thin Capitalisation regime, which will apply to income years commencing on or after 1 July 2023. In...

3 contributors

Melbourne

Insights

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Becky Nguyen

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Becky Nguyen

Becky Nguyen

Becky Nguyen

Becky Nguyen

2 contributors

Becky Nguyen

3 contributors

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