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  • Multinational Tax Integrity Package – denying deductions for payments relating to intangibles held in low - or no-tax jurisdictions

    On 25 October 2022, as part of the 2022–23 federal Budget, the government announced it proposes to introduce an anti-avoidance rule to prevent significant global entities (with global revenue of at least $1 billion) from claiming tax deductions for payments made directly or indirectly to related parties in relation to intangibles held in low or no-tax jurisdictions.

    These payments include royalties and payments in relation to other intangibles such as customers' databases and advertising algorithms. The measure will apply to payments made on or after 1 July 2023.

    For the purpose of this measure, a low or no-tax jurisdiction is a jurisdiction with either a:

    • tax rate of less than 15%
    • tax preferential patent box regime without sufficient economic substance.

    This measure delivers on the government's election commitment published in Our plan for a better future.

    The Bill has not been introduced to parliament and therefore is not yet law. Following consultations on the exposure draft Bill released in March 2023, the government has made changes to the draft Bill to better achieve the policy intent. The revised Bill and explanatory memorandum with the consultation summaryExternal Link were released for public information on 23 June 2023.

    Pending enactment of the new legislation, you can self-assess your tax liability under the existing law. If the law is ultimately changed retrospectively, you will need to seek an amendment.

    For more information, see:

      Last modified: 12 Jul 2023QC 70734