Australia redraws its capital gains base in the same week the global minimum tax becomes a return.

Parliament reshapes Australia's capital gains base as the Senate passes the Tax Reform No 1 Bills; the first GloBE Information Returns fall due on 30 June; and a cluster of 1 July measures, from an announced royalty penalty to the second tranche of the anti-money laundering regime, resets the compliance baseline for in-scope groups and their advisers.

The statutory due date for the first GloBE Information Return, for fiscal years ending on or before 31 December 2024, is 30 June 2026. In Australia the GloBE Information Return and the foreign lodgment notification carry the same statutory date for December balancers. The ATO's transitional compliance approach under PCG 2025/4 provides a 30 day administrative window to 30 July, during which lodgment enforcement is suspended and penalties may be remitted where a group has acted in good faith and taken reasonable measures to comply. The statutory date is not deferred; only the enforcement posture is softened.

Under the GloBE Rules a return must be filed in each implementing jurisdiction unless it is filed centrally in a jurisdiction that can exchange it under a qualifying competent authority agreement, and the OECD common understanding of 18 May relieves local filing only where the central return is timely and the specific exchange relationship is live. Access is the second constraint: the ATO asks affected groups to allow 10 to 28 days for any required Pillar Two account or role to appear, although most entities will have the account created automatically on first lodgement, with pre-action needed only where a new or different tax agent is nominated for Pillar Two.

Why it matters. With four days to the statutory date, the binding constraint for any group changing its lodgement agent is no longer the analysis but the account and role lead time, and a return that cannot be transmitted is not a lodged return.

What clients should do. Confirm the filing entity and lodgment channel for each in-scope jurisdiction, verify exchange activation before relying on central filing, resolve agent nomination and access issues now, and lodge by 30 June or make a deliberate, documented decision to rely on the 30 day window without slowing the data work.

On 1 June the OECD launched a public consultation on revisions to Chapter VII of the Transfer Pricing Guidelines, the first substantive reopening of the intra-group services chapter in a decade, with comments due by 22 July and a public event in Paris in November. The draft retains the simplified approach for low value-adding services but adds 21 worked examples and reorients the chapter around accurate delineation, a more refined benefit test, interconnected transactions, and a dedicated section on evidence and documentation.

The Australian backdrop sharpens the point. In February the Full Federal Court decided Commissioner of Taxation v S.N.A Group Pty Ltd [2026] FCAFC 10, denying service fee deductions under section 8-1 of the Income Tax Assessment Act 1997 because, once the earlier written agreements had lapsed, no contract subsisted to support the payments; internal bookkeeping labels and inferred conduct were not enough.

Why it matters. Service fees are the most common related-party flow and the most exposed on documentation, and both the draft and the case reward the same behaviour: current written agreements, a consistent methodology, and an evidence trail from agreement to invoice to payment.

What clients should do. Map material service-fee flows against the draft now, remediate where the benefit test rests on assertion, confirm every material arrangement is supported by a current unlapsed agreement, and consider a submission by 22 July on significant or contested arrangements.

On 25 June the Senate passed the Treasury Laws Amendment (Tax Reform No 1) Bill 2026, with amendments, and the Income Tax Rates Amendment (Tax Reform No 1) Bill 2026, without amendment; both await assent. The package replaces the 50% capital gains tax discount for individuals, partnerships and trusts with cost base indexation, and introduces a 30% minimum tax on net capital gains, directed at Australian-resident individuals, for gains accruing on or after 1 July 2027. For existing assets the mechanism is a notional sale and reacquisition at market value on 1 July 2027, with the current 50% discount applying to the gain to that date and indexation and the minimum tax applying afterwards. The reform reaches pre-CGT assets and requires a two-tier cost base to be tracked.

On negative gearing, deductions on established residential property are restricted: interests acquired on or after 7:30pm AEST on 12 May 2026 will not support negative gearing from 1 July 2027, with excess deductions quarantined against future residential capital gains, while pre-12 May 2026 holdings and new builds are unaffected. The Senate amendments of 18 June, agreed with the Australian Greens, also confine future SMSF limited recourse borrowing to business real property, lift the small business active asset turnover threshold from 2 million to 10 million dollars, and add a Working Australians Tax Offset and a 1,000 dollar standard work-related deduction.

Why it matters. This is not only a private client matter: trusts holding CGT assets on 1 July 2027 may need to revisit their taxable Australian property analysis at the reset point, and foreign-resident beneficiaries and investors should model the interaction with the separately progressing foreign resident CGT changes.

What clients should do. Begin modelling now rather than on assent: identify holdings straddling the 1 July 2027 reset, quantify and evidence the value at that date, map exposure to the minimum tax against the indexation method, and factor the borrowing and cost base changes into any property acquisition or restructure before commencement.

The new income year opens on 1 July with a cluster of changes that collectively reset the baseline. The announced significant global entity royalty mischaracterisation penalty is slated to commence on 1 July 2026 but remains unlegislated, with no bill before Parliament, so its legal force is contingent even as its policy signal is clear: royalty and embedded-royalty positions, particularly where royalty withholding tax has been avoided through characterisation, are an ATO priority.

The second tranche of the anti-money laundering and counter-terrorism financing regime commences on 1 July, extending designated-service obligations to accountants, lawyers, conveyancers, real estate agents and trust and company service providers, with AUSTRAC enrolment due 29 June. For multinational groups the practical consequence is more rigorous onboarding and verification at their Australian advisers.

Why it matters. The standing significant global entity penalty regime already doubles administrative and scheme penalties and increases failure-to-lodge penalties, so a higher penalty baseline, an elevated transfer pricing evidentiary expectation, sharper royalty scrutiny and a redrawn capital gains base raise the cost of a weak position on several axes at once.

What clients should do. Treat 1 July as a governance reset: finalise royalty and embedded-royalty reviews before the year turns, confirm advisers are anti-money laundering ready, and carry only transfer pricing, royalty and structuring positions you would defend on today's documentation.

Tax Reform No 2 Bill introduced. A second Budget package was referred to the Senate Economics Legislation Committee for report by 13 August 2026, introducing a new loss carry back for corporate tax entities, making the 20,000 dollar instant asset write-off permanent for small businesses, and providing a targeted income tax exemption.

Discretionary trusts: 30 per cent minimum tax. A 30 per cent minimum rate of tax on income distributed to certain resident beneficiaries of discretionary trusts is slated to apply from 1 July 2028, with franking credits potentially becoming non-refundable at the trust level for affected distributions.

Foreign resident CGT and thin capitalisation. The expansion of the foreign resident capital gains tax regime and the announced review of the thin capitalisation rules both remain live and bear directly on inbound structures; groups relying on the third party debt test at a 30 June balance date should confirm the conditions are evidenced for the year.

International Dealings Schedule. The ATO has updated the 2026 International Dealings Schedule instructions; groups completing the IDS should work from the current instructions, particularly on the transfer pricing, debt and Pillar Two adjacent disclosures.

Royalty characterisation. Royalty and embedded-royalty characterisation remains the single most likely trigger for significant global entity scrutiny; software, distribution and intra-group licence arrangements should be reviewed against the current ATO view before positions are locked.

A working view of the milestones now in play for in-scope groups. The statutory GloBE Information Return 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.