Eleven days to 30 June, and the rulebook is still being written in flight.

Eleven days to 30 June: the OECD issues an eleventh-hour rulebook to keep the first GloBE Information Returns lodgeable, reopens the transfer pricing of intra-group services for the first time in a decade, and Australia's filing window opens under PCG 2025/4 even as a 1 July royalty penalty looms unlegislated.

On 8 June 2026 the OECD released Guidance on the use of the GIR XML Schema for the first GloBE filing and exchange cycle, approved by the Inclusive Framework on 3 June 2026. It identifies fourteen issues in the current GIR XML Schema or its validation rules and prescribes practical workarounds: substitute elements, additional data points, dummy values, bounded percentage values, and the switching-off of certain validation rules. It openly accepts that gaps exist between the GIR template, the schema and the validation rules, and gives taxpayers and administrations a common way to proceed without delaying the 2026 filing and exchange timetable.

The guidance is, in substance, an admission that the machinery for the first exchange cycle is not production-ready weeks before it binds. The practical consequence is a divergence between a return that is technically valid against the schema and a return that is correct: a group that built its first filing to the literal schema may produce a clean file that is wrong, or a correct file that fails validation. For the first cycle, the operational risk has moved from whether the position is right to whether the file will lodge and exchange at all.

What clients should do. Confirm this week that your filing software or provider has incorporated the June workarounds; do not treat a clean validation pass as evidence that the return is correct; and reconcile each GIR data point back to the source workpapers and to the country-by-country report, because the regulator will cross-read the three. Where a third-party provider lodges, obtain written confirmation that the schema fixes are in their current build before the 30 June cycle, not after.

On 1 June 2026 the OECD published a public consultation proposing a rewrite of Chapter VII of the Transfer Pricing Guidelines, which governs intra-group services. The draft rebuilds the chapter around accurate delineation, requiring an analysis of the actual commercial and financial relations between the parties before the benefit test is applied; it refines the benefit test, expands the guidance on interconnected transactions, and adds a dedicated section on evidentiary and documentation considerations. Critically, it confirms that cost-based methods should not automatically be treated as the most appropriate method, and that a profit split may be appropriate where the parties make unique and valuable contributions or share economically significant risks. Comments close on 22 July 2026.

This matters because management fees, head-office recharges and shared-service charges are the most common related-party flows in the Australian inbound and outbound population. Moving the entry point from whether a benefit exists to what was actually agreed and done raises the documentation bar and directly challenges the reflexive cost-plus approach that underpins most service-fee policies. Read alongside the Commissioner's long-standing scrutiny of offshore service and procurement hubs, the direction of travel is unambiguous: the arrangement must be established before it is priced.

What clients should do. Revisit service-fee models now, stress-test cost-based mark-ups against the delineation-first framework, and prepare documentation that establishes the commercial reality of the arrangement before it prices it. Groups with material service flows into or out of Australia should consider lodging a submission by 22 July, particularly on the treatment of shareholder activities, the choice of allocation keys, and the inclusion of share-based remuneration in the cost base.

For December 2024 balancers the first GIR and the foreign lodgment notification are statutorily due on 30 June 2026, a date the Commissioner has confirmed he has no power to defer. The relief sits elsewhere: the two domestic returns, the domestic minimum tax return and the Australian IIR and UTPR return, receive an automatic 30-day deferral to 30 July 2026; an equivalent 30-day suspension of enforcement applies to the foreign lodgment notification for the first year; and PCG 2025/4 remits late-lodgment penalties in full for groups that can demonstrate good faith and reasonable measures, across a transition period covering fiscal years commencing on or before 31 December 2026 and ending on or before 30 June 2028. A designated local entity (DLE) may lodge on behalf of all Australian constituent entities, and a single foreign lodgment notification may be made by the DLE where the GIR is filed by a foreign parent or designated filing entity.

The deferral addresses lodgment, not data and not payment: any first-year top-up liability remains payable on the original date, so a group with a liability must fund it before its return is lodged. The good-faith and reasonable-measures standard is evidentiary, which means the contemporaneous record of the steps a group took is itself part of the compliance product, not a footnote to it. Incorrect lodger-type selection, that is, DLE against standalone, and entity details that do not match current ATO records are the predictable causes of rejected or delayed lodgments.

What clients should do. Lock the DLE nomination this week and confirm which Australian entities rely on the DLE and which must lodge their own foreign lodgment notification; document the reasonable-measures steps as you take them rather than reconstructing them later; and diarise any first-year payment for the statutory date, not the deferred lodgment date.

The Government has announced that, from 1 July 2026, significant global entities found to have mischaracterised or undervalued royalty payments to which royalty withholding tax would otherwise apply will face a new penalty. The measure replaced the earlier proposal to deny deductions for payments connected with intangibles held in low corporate tax jurisdictions, which was discontinued. As at this week the measure is not legislated and no draft Bill is before the Parliament.

A commencement date eleven days away with no Bill is, on any realistic view, unlikely to bind on 1 July in its announced form. The policy signal, however, is unambiguous, and it aligns with the enforcement posture the Commissioner has maintained since the High Court's 2025 decision in the PepsiCo litigation on embedded royalties. Exposure in this area is in practical terms retrospective regardless of the penalty's start date: the characterisation question reaches every distribution, software, franchise and licensing arrangement that bundles a right to use intangible property with something else, and the audit window does not wait for the penalty to commence.

What clients should do. Review bundled cross-border payments for embedded royalties now; document the basis for any split between a payment for services and a payment for the right to use intangible property; and treat the announced penalty as a statement of audit priority to be managed this year rather than a future event to be deferred until the legislation appears.

On 20 February 2026 the United States Supreme Court held, by six to three, that the tariffs imposed under the International Emergency Economic Powers Act were unlawful, invalidating both the reciprocal tariffs on most trading partners and the measures directed at China, Canada and Mexico. The Administration's response was immediate: a proclamation the same day invoked Section 122 of the Trade Act of 1974 to impose a temporary 10 per cent surcharge on almost all imports through to 24 July 2026, and although the Court of International Trade struck that surcharge down on 7 May, the Federal Circuit stayed that ruling on 11 June, so the duty continues to be collected pending appeal. The other instruments are untouched: on 15 June the Supreme Court declined to revisit the China Section 301 tariffs, closing the principal refund avenue for those duties, while Section 232 and the termination of de minimis treatment remain in force and an 8 June Section 232 proclamation eased the rate on a schedule of agricultural, mobile industrial and climate-control machinery from 25 per cent to 15 per cent through to the end of 2027.

For multinationals the headline is uncertainty and re-pricing. Refund prospects are now split: duties paid under the invalidated IEEPA measures may be recoverable, but the Section 301 route is closed and the Section 122 surcharge keeps accruing, so cash-flow exposure persists even while a measure is under appeal. The surviving lines keep tariff cost embedded in the customs value of imported goods, which interacts directly with related-party pricing: a transfer price that moves the customs value moves the duty payable, and a duty that moves margins feeds back into the arm's length test. Tariff policy has ceased to be a procurement matter sitting outside the tax function.

Thin capitalisation and DDCR review underway. Treasury's review of the thin capitalisation and debt deduction creation rules commenced on 1 February 2026, with a final report due by 1 February 2027. The review opens the prospect of recalibration of the earnings-based tests and the debt deduction creation rules that have unsettled inbound-geared groups since 2024; affected groups should keep restructure decisions under review rather than locking in long-dated positions before the report lands.

Side-by-side amendments to be legislated. Consistent with the Federal Budget 2026-27, the Government will amend the global and domestic minimum tax law to implement the OECD side-by-side package, including the carve-out of United States-parented groups from the income inclusion and undertaxed profits rules and the new and extended safe harbours, with effect from 1 January 2026. Australian-parented groups remain fully inside the IIR and UTPR net while US-parented competitors are carved out, an asymmetry that shifts relative effective tax rates in third markets and should be reflected in acquisition and investment modelling.

Public country-by-country reporting bedding in. Australia's public CbC regime applies to reporting periods commencing on or after 1 July 2024, with the first public reports for June 2025 balancers due by 30 June 2026 and publication to follow. In-scope groups should reconcile the public dataset against the GIR and the OECD country-by-country report before lodgment, because the three filings will be read together and inconsistencies will be visible to the regulator and, in part, to the public.

Tranche 2 AML/CTF commences 1 July 2026. Lawyers, accountants and other professional advisers come within the AML/CTF regime from 1 July 2026, with customer due diligence applying to designated services from commencement. Advisory firms, and the clients they onboard, should confirm that their onboarding, verification and record-keeping settings are in place before the start date.

High Court hands down Bendel on Division 7A. In FC of T v Bendel [2026] HCA 18 the High Court dismissed the Commissioner's appeal by five to two, holding that on the facts a corporate beneficiary's unpaid present entitlements were not loans for Division 7A purposes. The decision is fact-specific rather than a blanket clearance: it turns on the trust deed and resolutions creating a separate trust rather than a debtor-creditor relationship, and the ATO has said it will update its interim Decision Impact Statement. The exposure is sharpest for privately held Australian groups, where trust deed wording, distribution minutes and financial-statement descriptions should be reviewed, and present entitlement confirmed as at 30 June, before year end.

Tax Reform No 1 Bill advances with amendments. The Treasury Laws Amendment (Tax Reform No 1) Bill 2026 is before the Senate, with the Economics Committee due to report on 19 June and debate to follow in the next sitting week. Government amendments raise the small business active-asset 50 per cent CGT reduction turnover threshold from $2 million to $10 million, introduce a new 50 per cent CGT concession for innovative start-ups, and confirm that deductible gifts and donations reduce capital gains caught by the proposed minimum tax. A separate 30 per cent minimum tax on discretionary trust distributions remains slated for 1 July 2028, a change that would materially reduce the appeal of distributing to corporate beneficiaries.

A working view of the Pillar Two milestones now in play for in-scope groups. The statutory GIR date has not moved; only the enforcement posture has. Confirm each entity's obligation against its local rules, and verify exchange activation before relying on central filing.