Insights

Pillar Two Compliance in Australia: Why Outbound Multinational Groups Must Act Now

Pillar Two Has Arrived: Far More Than Another Reporting RequirementInternational tax reform has accelerated in recent years, but only a small number of initiatives have materially reshaped how multinational groups are governed, structured, and managed. Pillar Two is one of them.Developed in response to concerns around base erosion and profit...

2 contributors

Melbourne

Insights

Final ATO guidance on restructures and the thin capitalisation and debt deduction creation rules – PCG ²⁰²⁵⁄₂

On 20 August 2025, the Australian Taxation Office (ATO) released PCG 2025/2, providing its final compliance approach to restructures undertaken in response to restructures, the new thin capitalisation rules and debt deduction creation rules (DDCR) introduced by the Treasury Laws Amendment (Making Multinationals Pay Their Fair Share—Integrity and Transparency) Act 2024. This guideline offers a risk assessment framework and practical examples to help taxpayers self-assess the compliance risk of their restructuring arrangements.

Becky Nguyen

Partner

Melbourne

Insights

ATO Draft PCG 2025/D4: a practical guide for low-risk software payments

On 6 August 2025, The Australian Taxation Office (ATO) released Draft Practical Compliance Guideline PCG 2025/D4, providing a targeted compliance framework for low-risk cross-border software payments. While narrow in scope, this guidance offers taxpayers an opportunity to reduce uncertainty and better manage compliance in a specific area of tax administration.

Becky Nguyen

Partner

Melbourne

Insights

Pillar Two Implementation in Australia: ATO releases further guidance on reporting obligations

Following the initial rollout of Pillar Two rules in Australia, the Australian Taxation Office (ATO) has now released further guidance detailing the lodging, payment, and compliance obligations for multinational enterprise (MNE) groups under the Global Anti-Base Erosion (GloBE) framework.

Becky Nguyen

Partner

Melbourne

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

Essential insights for Multinational Enterprises: Compliance approach for restructures of financing arrangements

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 TestWhat...

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 structured...

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 advisers.PKF Australia's contribution to this newsletter was authored by Becky Nguyen from PKF Melbourne. Below,...

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

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

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Becky Nguyen

Becky Nguyen

Becky Nguyen

Becky Nguyen

Becky Nguyen

Becky Nguyen

Becky Nguyen

Becky Nguyen

Becky Nguyen

3 contributors

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