Australia

Under the superannuation guarantee (SG) scheme, which requires employers to contribute a certain percentage of an employee's earnings base, subject to limited exceptions, to a registered superannuation fund or retirement savings account on behalf of the employee, the required SG percentage increased to 11.5% from 1 July 2024 and will remain so until 30 June 2025, at which time it will increase to 12%. See the Other taxes section for more information.

The tax treaty with Iceland has entered into force to apply from as early as 1 January 2024. See the Withholding taxes section for more information.

Effective for income years commencing on or after 1 July 2023, new thin capitalisation rules apply to multinational entities (other than finance entities and authorised deposit taking institutions) to limit debt deductions using earnings based tests or a third party debt test. Furthermore, with effect for income years commencing on or after 1 July 2024, new debt deduction creation rules can apply to deny deductions for costs of related-party debt used to fund the acquisition of certain capital gains tax (CGT) assets from an associate or to fund certain payments and distributions to associates. See the Group taxation section for more information.

The government has stated that additional scrutiny will be applied to foreign investment proposals with certain tax characteristics likely to be considered higher risk. Furthermore, a new ‘Register of foreign ownership of Australian assets’ (FIRB asset register) commenced on 1 July 2023, requiring ‘foreign persons’ (which broadly covers foreign entities and Australian entities with upstream foreign ownership) to register a broad range of assets.  See the Other issues section for more information.

Australia will be implementing the Global Anti-Base Erosion (GloBE) Rules, a key component of the Organisation for Economic Co-operation and Development's (OECD’s) Two-Pillar Solution to address the tax challenges of digitalisation of the economy with an effective date for some measures as early as income years commencing on or after 1 January 2024, in addition to a 15% domestic minimum tax applying to income years starting on or after 1 January 2024. See the Taxes on corporate income section for more information.

The Government’s proposal to deny deductions for payments made from 1 July 2023 by a significant global entity to related parties that relate to intangibles held in a low or no-tax jurisdiction is no longer proceeding. See the Group taxation section for more information. 

Greater tax transparency measures apply to multinationals including an obligation for Australian public companies to report additional information about subsidiaries, including their tax residency, in relation to financial reporting periods commencing on or after 1 July 2023, and for certain large multinational groups which will be required to publicly disclose certain tax information on a country by country basis for income years commencing on or after 1 July 2024 See the Other issues section for more information.