The mischaracterisation or undervaluation of interest and dividends?

The potential breadth of the rules for significant global entities, foreshadowed in the 2024-25 MYEFO announcement, raises a number of questions on how they would be implemented, as outlined by Julian Humphrey, Denis Larkin, John Fulton and Ethan Zuo.

The 2024-25 Mid-Year Economic and Fiscal Outlook (MYEFO) document included the following 'sleeper': "The Government will amend the tax law to strengthen Australia's current tax penalty regime by…penalising large taxpayers that mischaracterise or undervalue interest or dividend payments, to which withholding tax would otherwise apply, starting from 1 July 2026." This announcement effectively extended the 2024 Budget announcement of a similar rule in relation to royalties to replace th...

Sign in below or register now to read the full article

Authors: Julian Humphrey, Denis Larkin,

Published Date: 26 May 2025