Hilton International Australia Pty Ltd v Commissioner of Taxation (No 2) [2026] FCA 1325 (9 September 2026) highlights the importance of being able to explain and evidence why a particular structure was adopted, including why it was commercially preferable to alternatives.
This review is essential to independently determining whether the rules operate and produce outcomes in line with their intended policy objectives.
With the legislation expected to be introduced to Parliament in the next two weeks, we will see the mechanism chosen by Treasury to effect this change, as highlighted by Julian Humphrey, Brent Murphy, Alia Lum and Amanda Maguire.
This report analyses how the application of different types of tax incentives may trigger a potential Top-up Tax exposure for MNE Groups in scope of the GloBE rules.
KPMG Tax Analytics and Automation Partner Barry Sullivan outlines why organisations aren’t just looking for efficiency; they want automation that delivers real insights and supports strategic decisions, not just faster tasks.
The new filing obligation represents a significant shift in UK transfer pricing compliance and risk management, as outlined by KPMG UK’s Phil Roper.
An increasing number of interpretative challenges have been identified for the application of the Pillar Two joint venture rules, as highlighted by Conrad Turley and Marco Dietrich.
The regulator says it plans to take a pragmatic and proportionate approach to its supervision and enforcement of these requirements.
This report revisits the key criteria that determines if your business is a reporting entity, providing clarity on thresholds, timelines, and responsibilities.
In Australia, Pillar Two has been substantively enacted and applies to half years and years ended 30 June 2025.
Taxpayers should consider the broader commentary within the draft PCG as to what the ATO considers are the key ‘hallmarks’ of a commercially-minded borrowing decision, and compare their own related party debt, as detailed by Sean Madden and Sam van Berkel.
This report seeks to provide an informative and insightful analysis of how these developments are influencing tax functions and how the business environment and direction of tax policy is likely to evolve in the years to come.
This episode explores how companies are meeting their tax obligations when it comes to intangible assets, such as software royalties, what cross-border issues are arising and the current level of activity and guidance coming from tax administrators.
The ATO reiterated the importance of tax governance processes, noting basic tax errors would decrease through the implementation of a documented tax governance framework, as discussed by Keith Swan, Belinda Cheesewright, Blake Indian, Aylin Harapoz and Sydney Karampour.
Preliminary modelling by KPMG, including the retail sales volumes data released in October, suggests household consumption for 2024Q3 will show another quarter of negative growth, as detailed by Brendan Rynne.
KPMG US’ John Gimigliano and Dan Winnick revisit the Biden Administration’s Green Book revenue raising proposals and then discuss Kamala Harris’ proposals for new tax cuts.
For large market taxpayers who have either not undergone a GST assurance review or are new entrants to the Top 100 and Top 1,000 populations, this return acts as a timely reminder of the ATO’s focal points, as outlined by Anthony Versace, Jacqui Hardwick and Roseanne Ross.
