Global Daily Tax News, Australia Set To Release New Int'l Tax Guidance, (Apr 1, 2025)

The Australian Taxation Office has announced it will soon release two new guidance documents on international tax matters.

Public CBC parent entities are required to lodge a public CBC report for reporting periods commencing on and after July 1, 2024, unless they have been granted an exemption by the Commissioner. The agency has said it will soon release guidance on the Commissioner's approach to Public Country-by-Country (CBC) reporting exemptions.

The guidance will clarify:

• the process for submitting applications;

• information that should be provided with applications; and

• considerations relevant to the exercise of the discretion sought.

The ATO said the guidance will provide instruction to officials on exercising these powers and provide guidance to applicants on seeking an exemption.

Second, the ATO intends to release one guide, of three planned, on Australia's new thin capitalization rules. This guidance will focus on broad-based principles for taxpayers when assessing their cross-border related party finance arrangements.

The ATO intends to use the guidance to flag areas of concern regarding specific features of financing arrangements and related transfer pricing.

In a March 30, 2025, update to its website, the ATO has said both guides can be expected in mid 2025.