web
You’re offline. This is a read only version of the page.
close
Most Popular Articles
Courts provide welcome clarity of ‘real property’ under Division 855
In two decisions handed down over the last fortnight, the Federal Court has d...
Upcoming foreign Pillar Two compliance deadlines
While the first Pillar Two filings are due in Australia in mid-2026, many in-...
Draft instructions released for Australian Public Country-by-Country report
The Australian Taxation Office (ATO) has released draft Instructions for comp...
Redesigned Voluntary Tax Transparency Code released by Board of Tax
The Board of Taxation (BoT) has finalised its redesign of the Voluntary Tax T...
News View all >
News in brief… 18 November 2025
Tasmanian Government consults on new business Single Start-Up Permit; ATO update: Alert issued on ‘barter credits’ tax scheme
News in brief… 17 November 2025
ATO update: International summit on tackling tax evasion; US modifies tariffs to exclude agricultural products
News in brief… 14 November 2025
Victoria’s Revenue Office consults on property tax notification default draft revenue ruling; ATO update: Understanding the effects of thin capitalisation rules, DDCR on debt deductions; ATO update...
News in brief… 13 November 2025
Treasury releases working paper on Australian M&A transactions database; ASIC outlines enforcement priorities for 2026; Investor confidence sees number, value of new investment loans reach record h...
Latest Content
Australian inflation and cost dynamics – November 2025
Inflation pressures in Australia have rebounded in the September quarter, with headline inflation surging above the Reserve Bank of Australia's (RBA) target range for the first time in over a year. While supply pressures remain persistent - particularly in energy, demand-side factors have strengthened after a period of subdued consumption. KPMG expects inflation will remain contained despite ...
Joint ventures and Pillar Two – Applying the rules
The Pillar Two joint venture (JV) concept, first set out in the 2021 Model Rules, might be viewed as a narrowed version of the original idea, in the 2020 Pillar Two Blueprint, to subject associates (in which a multinational enterprise (MNE) had a 20 percent and above holding) to Pillar Two tax. The Pillar Two JV concept is quite particular and can differ from the JV concept under accounting st...
Upcoming webinar: Insurance Tax update
KPMG would like to invite you to attend our Insurance Tax Update event. We will update you on various direct, indirect and international tax matters impacting the insurance industry. Date: Thursday, 4 December 2025 Time: 9:00am - 10:00am AEDT Location: Webinar Register here
Podcast episode 72: Finding the real ROI by outsourcing salary packaging administration
ATO draft ruling restricts deductions for short term rental properties
The rapid expansion of online platforms such as Airbnb have undoubtedly influenced the landscape of the Australian property market. Approximately 250,000 or 2 percent of the nation's housing stock is currently held for the purposes of operating as short-stay or holiday accommodation. Many of these properties are negatively geared, providing potentially significant tax breaks to owners and inv...
How do US-Asia trade agreements affect DSTs, FDDEI and VAT?
The United States (US), on October 26, announced trade agreements with Cambodia and Malaysia and framework agreements with Thailand and Vietnam. Although the agreements primarily impact bilateral trade between these countries and the US, and particularly the rate of customs duties imposed, various provisions and statements focus on other tax issues. Digital Services Taxes The Cambodian and M...
Hall and Commissioner of Taxation – home office deductions in the work-from-home era
In case you missed it, there was a relatively big case decided in May this year on the deductibility of work from home expenses. The Australian Taxation Office (ATO) has lodged an appeal to the Federal Court. This article provides a quick recap of the case and its relevance to your own individual tax return with a 'watch this space' for the appeal. Overview The recent Administrative Review ...
Upcoming webinar: Payday Super - A new era in Superannuation compliance
Payday Super has completed its passage through Parliament paving the way for substantive reform to the Superannuation Guarantee landscape. In our latest webinar we will explore: a recap of what Payday Super is about, and when it takes effect; the key changes from the exposure draft to the final Bill; the short-term safe harbour being offered in the draft version of PCG 2025/D5 Payday Supe...
Courts provide welcome clarity of ‘real property’ under Division 855
In two decisions handed down over the last fortnight, the Federal Court has dismissed the Commissioner's very broad view of the meaning of 'real property' under Division 855 of the Income Tax Assessment Act 1997 (Cth) (Division 855). The Courts have emphatically confirmed that 'real property' must be understood in its technical, legal sense, and expressly rejected the Commissioner's expansive i...
Rising tide fails to lift all boats – a jobless boom
President John F. Kennedy first coined the phrase "a rising tide lifts all boats" in a 1963 speech. The problem is that all boats do not rise with the tide. Some are not seaworthy, others are anchored in place and too many lack the means to own a boat. That seemed an apt metaphor for where we are. The economy is powering forward, aided by a boom in AI, or arms race, as many in Washington se...
Upcoming webinar: Banking and Finance Tax webinar
KPMG invites you to our next Banking and Finance Tax update. These events are specifically designed to keep banking and finance industry professionals up to date with current and emerging tax trends, and to share insights from our recent experience. Date: Thursday, 27 November 2025 Time: 1:00pm - 2:00pm AEDT Location: Webinar Register here Further details of the topics and speakers wi...
Upcoming foreign Pillar Two compliance deadlines
While the first Pillar Two filings are due in Australia in mid-2026, many in-scope multinational groups with offshore operations may be subject to earlier deadlines in some foreign jurisdictions – for Pillar Two registrations, tax payments and tax returns. Imminent top-up tax payment and filing deadlines Whilst the vast majority of jurisdictions have a due date for the first Pillar Two ...
Draft instructions released for Australian Public Country-by-Country report
The Australian Taxation Office (ATO) has released draft Instructions for completing the Australian Public Country-by-Country Report. The release of the draft instructions is an important and highly anticipated step in the implementation road map for Australian Public Country-by-Country (CbC) Reporting. The guidance provides practical information on the compliance requirements for in-scope gro...
Redesigned Voluntary Tax Transparency Code released by Board of Tax
The Board of Taxation (BoT) has finalised its redesign of the Voluntary Tax Transparency Code (VTTC). As outlined in our previous article, the VTTC is a set of principles and minimum standards to guide medium and large businesses on public disclosure of tax information.  The BoT, the body which developed and administers the VTTC, undertook to update and simplify the VTTC to better align ...
OECD holds annual ‘tax certainty day’, highlights MAP and APA statistics
The Organisation for Economic Cooperation and Development (OECD) Forum on Tax Administration (FTA) held its annual tax certainty day on 31 October 2025. This was the seventh annual event that coincides with the release of the 2024 Mutual Agreement Procedure (MAP) statistics and the 2024 Advance Pricing Agreement (APA) statistics. The day was based around a series of panels covering: MAP an...
Overhauling the Advance Pricing Arrangement framework, the ATO completes significant update
The Australian Taxation Office (ATO) has completed a significant update to its Advance Pricing Arrangement (APA) framework in PS LA 2015/4, more than two years after publishing findings from a review into the APA program. A framework due for modernisation The APA program has long been a foundation of the ATO's cooperative compliance approach, allowing Multinational Enterprises (MNEs) to agree...
Interest rate cut hopes for November all but dashed
Homeowners could miss out of a Melbourne Cup Day interest rate cut, with inflation surging above the Reserve Bank of Australia's (RBA) target range for the first time in more than a year. The consumer price index (CPI) hit 3.2 percent in the September quarter, marking the worst annual reading since the June quarter of last year, according to the Australian Bureau of Statistics latest data. Th...
European Union public country-by-country reporting – early lodgement deadlines approaching
The European Union (EU) public country-by-country reporting (CbCR) rules are now in effect, with some EU Member States opting for early lodgement deadlines. As such, Australian-headquartered multinational groups with operations in Europe should ensure they are prepared for any approaching compliance deadlines for this new mandatory reporting measure. For some Australian-headquartered multinat...
‘Stay Away’: Full Federal Court backs Oracle in significant decision
The Full Federal Court (Hespe, Button and Younan JJ), on 21 October 2025, unanimously allowed Oracle's appeal, overturning Perram J's earlier decision to refuse to stay proceedings in favour of MAP with Irish authorities. With no public interest factors weighing against a stay, the Full Court determined that the Double Tax Agreement ('DTA') and Multilateral Instrument ('MLI') supported pausing ...
Upcoming webinar: EU tax perspectives
European tax policy continues to evolve in response to a changing global policy and economic landscape. As policymakers continue to focus on simplification and competitiveness, businesses will be watching closely to understand the direction of EU tax reform and how it may impact them. Date: Thursday 27 November Time: 2AM AEDT Location: Webinar Register here As the Cypriot presidency p...
United States’ inflation slows upward creep, with services sector inflation proving sticky
The United States' consumer price index (CPI) rose 0.3 percent in September from August and 3.0 percent from a year ago. That is the hottest annual pace since the beginning of this year. Data in the more recent months was revised up slightly. This could be the last solid data point on inflation for months as the US Government shutdown stopped data collection 1 October. Staffing shortages alr...
Webinar recording: European financial services tax perspectives
The European tax landscape is shifting fast and financial services institutions are feeling the impact. With BEPS Pillar 2 implementation underway, firms are facing new challenges around global minimum taxation, substance requirements, and much more. At the same time, EU directives are reshaping compliance expectations, while local tax authorities ramp up enforcement. Add to that the growing...
Cleaning up payroll tax: How the SKG decision sweeps in employment agency arrangements
The Supreme Court of New South Wales (NSW), on 17 October 2025, delivered its decision in SKG Cleaning Services Pty Ltd v Chief Commissioner of State Revenue; Ezko Property Services (Aust) Pty Ltd atf The Ezko Unit Trust v Chief Commissioner of State Revenue [2025] NSWSC 1219, upholding payroll tax assessments against commercial cleaning companies SKG and Ezko. The outcome of the decision impac...
Upcoming webinar: Big Beautiful Bill - Strategic insights for inbound companies
The One Big Beautiful Bill Act (OBBBA) has ushered in sweeping changes to the United States (US) tax landscape, with significant implications for foreign-parented multinationals operating in the US. This webinar will provide a strategic overview of the inbound-specific provisions of the OBBBA, focusing on how these reforms reshape planning, compliance, and reporting for inbound structures. Part...
US Fed has duelling mandates, with ‘no risk-free path’
The United States (US) Federal Reserve’s dual mandate - to foster price stability and full employment - is rapidly morphing into a duelling mandate. The Fed’s Beige Book revealed that the labour market remains stuck in its low hire, low fire, stagnate mode, while inflation is accelerating. It noted stickiness in service sector inflation and incidents of opportunistic pricing. The...
Public country-by country reporting: Implementation state of play – September 2025
The Public Country-by Country Reporting (CbC) Reporting Directive is a minimum standard, leading to differences in domestic transposition. As there are no priority rules or guidelines on how the various implementing legislation interact, non-European Union (EU) multinational groups should monitor deviations from the Directive and analyse how these differences need to be addressed. Differences...
High Court unanimously confirms past, future validity of Queensland and Victorian land tax surcharges
The High Court of Australia, on 15 October 2025, handed down its judgement in the ongoing dispute on the constitutional validity of foreign surcharge land taxes and the impact of this decision is expected to extend to stamp duty surcharges and the other jurisdictions. The Court heard the G Global and Stott cases simultaneously due to their similarities[1]. Facts Proceedings involved two comp...
US Internal Revenue Service furloughs nearly 47 percent of employees
The partial United States (US) Government shutdown is into its third week with no immediate resolution likely. Furloughs have begun at the Internal Revenue Service (IRS) - nearly 47 percent of employees -potentially hindering operations. Most other Congressional action remains on hold with one significant exception: passage by the Senate of a bipartisan National Defence Authorisation bill. G...
Malaysia’s 2026 budget includes new tax proposals
The Ministry of Finance of Malaysia issued the 2026 budget on 10 October 2025, focusing on improving governance and broadening the tax base without introducing new taxes to achieve equitable taxation for high-income earners and foreign entities. Significant tax proposals include: review of tax exemption for foreign-sourced income: extension of tax exemption on foreign-sourced dividend in...
Upcoming webinar: BEPS Pillar Two path to compliance
Time is running out to prepare for BEPS Pillar Two. With rules already in effect across multiple jurisdictions and more launching soon, the window for compliance readiness is closing. Year-end tax provisioning, financial statements, and corporate tax return lodgement deadlines are all converging - placing immense pressure on tax and finance teams. If your preparation hasn't begun, the time t...
Taxpayer’s rights in ATO investigations: Insights from R v Clarke
Justice Smith of the Supreme Court of Queensland (Court) has published a lengthy 338-page decision resulting in an order for a stay of criminal prosecution of a medical researcher (defendant) in R v Clarke (a pseudonym) (No 9) [2025] QSCPR 17, in relation to allegations of tax (R&D) fraud. Key issues The defendant was charged under the Criminal Code (Cth) (Criminal Code) with attempting t...
Super Tax News – September Quarter 2025
The September Quarter 2025 edition of KPMG's Super Tax News covers the latest key superannuation tax updates including: Economic Reform Roundtable; Productivity Commission – Interim Report on 'Creating a more dynamic and resilient economy'; public country-by-country reporting; final revised ATO ruling – TR 2010/1A4; changes to deductibility of GIC and SIC payable to the ATO; ...
Payday Super legislation introduced, as consultation opens for a draft practical compliance guideline
The Federal Government, on 9 October, introduced Payday Super legislation into parliament, which would take effect on 1 July 2026. Notwithstanding that the Payday Super legislation is not yet law, employers that have been waiting for the legislation to be introduced into parliament before planning, now have a clearer picture of the specifics of how the legislation will apply. Importantly the ...
Upcoming webinar: Are you ready for 31 December 2025 Reporting?
This update will focus on preparing for interim and annual financial reporting at 31 December 2025 and highlight: new accounting standards effective and available for early adoption; and important regulatory developments and ASIC's focus areas. We will also touch on recent developments in Australian-specific sustainability reporting and provide a refresher on the recurring practical appl...
IFRS Interpretations Committee agenda decisions – September 2025 meeting
At its September 2025 meeting, the IFRIC approved two new tentative agenda decisions, which are now open for public comment. These relate to: classification of a foreign exchange difference from an intragroup monetary item under IFRS 18; and economic benefits from use of a battery under an offtake arrangement. The tentative agenda decisions are open for comment until 25 November 2025. ...
UK Economic outlook – September 2025
The prospect of tax rises in the United Kingdom's (UK) Autumn Budget dampens sentiment for both businesses and households. While rising inflation coupled with slowing wage growth could see household incomes squeezed, raising the likelihood of muted consumer spending over the coming quarters. Key takeaways A strong start to the year is expected to make way for a slower pace of growth for th...
Global lessons on fiscal rules: Independence, impact and integrity
KPMG International and Jericho hosted a roundtable discussion recently, bringing together global experts to explore the evolving role and effectiveness of fiscal councils around the world — and the lessons they offer for good governance, economic planning and public trust in times of uncertainty As countries navigate the dual pressures of rising public debt and demands for investment, th...
Podcast episode 71: Finding a place for Artificial Intelligence in tax functions
United States’ job openings fall to lowest in four years
The number of job United States (US) openings stayed flat in August. There were 7.2 million jobs available at the end of the month, according to the latest Job Openings and Labour Turnover Survey (JOLTS); that is the same as the month prior. The monthly data are noisy. On a three-month moving average basis, job openings have fallen to 7.2 million from a range of 7.4 to 7.8 million since June ...
Finalised ATO guidance on the third-party debt test released
The Australian Taxation Office (ATO), on 1 October 2025, released its finalised guidance on the third party debt test (TPDT), Taxation Ruling TR 2025/2 (the Ruling). The ATO also released its finalised guidance on restructures in response to the TPDT, included within Schedule 3 of Practical Compliance Guideline PCG 2025/2 (the PCG). The TPDT forms part of the new thin capitalisation rules whi...