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Tax Chat webinar series 2026

28/01/2026

Explore the latest in the world of taxation in our Tax Chat webinar series. Join us for engaging sessions on the most recent tax rulings, cases and key developments shaping the tax landscape. Stay ahead in a rapidly evolving tax environment with Tax Chat, our complimentary six‑part webinar series designed for SMEs, advisers and private […]

Developing trouble: ATO Alert on related party development management agreements

15/01/2026

The Australian Taxation Office (ATO) has issued Taxpayer Alert TA 2026/1, signalling increased scrutiny of common property development management agreement structures, which will substantially impact property developers. The Alert raises the ATO’s concerns about certain property development management agreements. These typical arrangements are used by taxpayers to segregate the development risks from the land-owning entity. […]

Pillar Two ‘Side-by-Side’ arrangement released by OECD  

08/01/2026

On January 5, 2026, the OECD announced a new ‘Side-by-Side’ (SbS) agreement, crafted to address concerns raised by the United States about the global minimum tax rules. The deal introduces administrative guidance and extends safe harbour mechanisms, aiming to simplify compliance for multinational enterprises (MNEs).   While the United States (US) is the first to qualify, other countries may also […]

QLD Foreign Tax Reforms: Merry Xmas for Queensland Developers

23/12/2025

The Queensland Government has announced sweeping changes to its foreign tax regime as part of the 2025–26 Mid-Year Fiscal and Economic Review (MYFER). These reforms aim to reduce barriers for Australian-based developers and encourage foreign investment into Queensland’s property sector. Queensland introduced the Additional Foreign Acquirer Duty (AFAD) in 2016 and the Foreign Land Tax […]

Rental properties and holiday homes: ATO’s new draft ruling

19/12/2025

On 12 November 2025, the Australian Taxation Office (ATO) released Draft Taxation Ruling TR 2025/D1 which seeks to clarify the assessable income of a rental property, provide stricter deduction eligibility for holiday homes, and clear up expense apportionment rules.    The ruling, titled Income tax: rental property income and deductions for individuals who are not in business (‘the ruling’), along with two practical guidance guides, replaces the longstanding IT […]

Unimproved land subject to Vacant Residential Land Tax from 1 January 2026

16/12/2025

Effective 1 January 2026, Vacant Residential Land Tax (VRLT) will apply to unimproved land in metropolitan Melbourne that has remained undeveloped for five consecutive years or more (as of 31 December of the preceding year).   The Victorian Government has released Treasurer’s guidelines outlining limited circumstances where the Commissioner may exercise discretion to exempt landowners from VRLT if construction has not commenced due to acceptable reasons.  What is VRLT and how has it […]

ATO Draft Determination TD 2025/D3: New guidance on when ancillary funds ‘provide a benefit’ 

15/12/2025

On 12 November 2025, the ATO released draft Taxation Determination TD 2025/D3, offering the first detailed guidance on when ancillary funds are considered to ‘provide a benefit’.  The draft provides the first comprehensive guidance on when private and public ancillary funds ‘provide a benefit’ under the Taxation Administration (Private Ancillary Fund) Guidelines 2019 and the Taxation Administration (Public Ancillary Fund) Guidelines 2022 (collectively, the Guidelines).  […]

ATO and income splitting – this time its personal

12/12/2025

The Australian Taxation Office (ATO) has issued Practical Compliance Guideline PCG 2025/5, a reminder that taxpayers are at risk of audit if personal services income is split to reduce tax.  The ATO has indicated that even if your business satisfies the statutory Personal Services Income (PSI) rules and operates as a Personal Services Business (PSB), your overall tax position may still be classified as either […]

Watt a relief! Capital gains relief for foreign investors in energy sector

03/12/2025

The Federal Court of Australia has handed down its decision in YTL Power Investments Limited v Commissioner of Taxation [2025] FCA 1317, ruling in favour of YTL Power (the Taxpayer) and holding that the infrastructure assets did not constitute real property.  The Taxpayer was successful in arguing that the leased electricity infrastructure situated on owned and leased land did not constitute “real property situated in Australia (including a lease of land)” and accordingly the shares disposed were not “taxable […]

Build-to-rent developments: ATO draft updates to GSTR 2012/6

20/11/2025

On 5 November 2025, the ATO issued a new draft taxation ruling GSTR 2012/6DC (‘the ruling’) expanding on existing principles provided in GSTR 2012/6 – Goods and services tax: commercial residential premises.   The draft ruling provides further clarity on how existing principles apply to build-to-rent (‘BTR’) developments, determining the status of occupants, and the characteristics […]