House of Representatives

Explanatory Memorandum

(Circulated by authority of the Assistant Minister for Productivity, Competition, Charities and Treasury, the Hon Dr Andrew Leigh MP)

Chapter 5: Machinery and other technical amendments

Outline of chapter

5.1 Schedule 5 to the Bill makes machinery and other technical amendments to Treasury portfolio legislation. The amendments demonstrate the Government's ongoing commitment to the care and maintenance of Treasury portfolio legislation.

5.2 The amendments correct unintended drafting outcomes, update legislative references, simplify provisions and reduce red tape. These amendments will enable ongoing administration of key government programs and address unforeseen outcomes of previous legislative changes that undermine the proper functioning of various government initiatives.

5.3 While similar in nature to the minor and technical amendments in Schedule 4 to the Bill, the machinery and other technical amendments in this schedule need to be in place as soon as possible to enable ongoing administration of key government programs and address unforeseen outcomes of previous legislative changes that undermine the proper functioning of various government initiatives.

Context of amendments

5.4 Amendments are periodically made to Treasury portfolio legislation to correct errors and unintended outcomes, make technical changes and improve the quality of Treasury portfolio legislation.

5.5 The process was first supported by a recommendation of the 2008 Tax Design Review Panel, which considered ways to improve the quality of tax legislation. It has since been expanded to all Treasury legislation

Summary of new law

5.6 Division 1 of Part 1 amends the Corporations Act; Division 2 of Part 1 amends the FATA; Division 3 of Part 1 amends the NRAS Act, Division 4 of Part 1 amends the CCA; and Part 2 amends the TAA.

5.7 The machinery and other technical amendments maintain and improve the quality of Treasury legislation by:

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ensuring that the law reflects current Machinery of Government changes;

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addressing unintended practices; and

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rectifying drafting errors;

Part 1 – Amendments commencing day after Royal Assent

Division 2—Education and training standard

Background

5.8 Part 7.6 of the Corporations Act deals with the licensing of providers of financial services in Australia. A person must be a 'relevant provider' in order to provide personal advice to retail clients in relation to relevant financial products. Relevant providers must either hold an AFS licence or be authorised by their AFS licensee, and must be registered with ASIC.

5.9 The Corporations Amendment (Professional Standards of Financial Advisers) Act introduced professional standards for relevant providers, comprising four education and training standards (section 921B of the Corporations Act):

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The first is a 'qualifications standard', which generally requires a relevant provider to have completed an approved bachelor or higher degree.

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The second is an 'exam standard', which requires a relevant provider to have passed the financial adviser exam.

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The third is a 'professional year standard', which requires a relevant provider to undertake a year of work and training.

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The fourth is a 'continuing professional development standard', which requires a relevant provider to undertake additional training.

5.10 The FASEA was approved as the standards setting body, responsible for approving qualifications, administering the exam and setting requirements for the year of work and training and continuing professional development.

5.11 Section 921BA of the Corporations Act imposes obligations on relevant providers to meet these education and training standards, with civil penalties for failing to comply. Under section 921C of the Corporations Act, a person who has not met the education and training standards cannot be licensed or authorised to provide personal advice to retail clients in relation to relevant financial products and would need to cease providing such advice.

5.12 The Corporations Amendment (Professional Standards of Financial Advisers) Act also included transitional arrangements for 'existing providers' of financial advice to meet the new education and training standards. This included establishing an alternative pathway for existing providers to meet the qualifications standard. This pathway allows existing providers to complete approved "top up" courses. The application of the qualifications standard was also delayed for existing providers so they would have more time to undertake additional studies (if necessary) and provided additional time for existing providers to pass the exam. For clarity, these transitional arrangements are different to the experienced provider pathway for meeting the qualifications and professional year standards. The experienced provider pathway was introduced via the Treasury Laws Amendment (2023 Measures No. 3) Act 2023 (see section 1684AA of the Corporations Act).

5.13 An existing provider is generally a person who was a relevant provider at any time between 1 January 2016 and 1 January 2019, who was also not not banned, disqualified, or otherwise prevented from providing personal advice to retail clients in relation to relevant financial products on 1 January 2019 (section 1546A of the Corporations Act).

5.14 The Financial Sector Reform (Hayne Royal Commission Response—Better Advice) Act transferred the professional standards setting functions from FASEA to the Minister responsible for the Corporations Act and to ASIC from 1 January 2022. It also set out the consequences for existing providers of failing to pass the exam by the exam cut off day (1 January 2022) and failing to meet the qualifications standard by the end of the transitional period (1 January 2026). Otherwise, it purported to maintain the existing education and training standards including the transitional arrangements for existing providers.

5.15 The Financial Sector Reform Amendment (Hayne Royal Commission Response – Better Advice) Regulations 2021 extended the exam cut off day to 1 October 2022 for existing providers who sat the exam at least twice before 1 January 2022. For all other existing providers, the exam cut-off day remained 1 January 2022.

5.16 Under the alternative qualification pathway in section 1684A of the Corporations Act, an existing provider can meet the qualifications standard by completing the necessary top up course(s) determined by the Minister under subsection 1684E(1) of the Corporations Act. This alternative qualification pathway is outlined in sections 7 and 8 of Part 3 of the Corporations (Relevant Providers Degrees, Qualifications and Courses Standard) Determination 2021. This pathway requires the completion of between one and eight additional units of study, depending on the existing provider's qualifications.

5.17 The Financial Sector Reform (Hayne Royal Commission Response—Better Advice) Act inadvertently removed access to the alternative qualification pathway for existing providers who are relevant providers on 1 January 2026. The Explanatory Memorandum to the Bill for that Act states that the Bill "maintains the existing application of the law" and the intention was to ensure "continuity and certainty of obligations for financial advisers". However, section 1684A of the Corporations Act as currently written does not achieve this continuity to enable certain existing providers to have the option of meeting the qualifications standard via the alternative qualification pathway, irrespective of whether they are a relevant provider on 1 January 2026. The consequence of the error in the current law is that existing providers who are relevant providers on 1 January 2026 cannot rely on the alternative qualification pathway.

5.18 Item 10 amends the Corporations Act to align the operation of the law with the policy intent of the Corporations Amendment (Professional Standards of Financial Advisers) Act to ensure that the alternative qualification pathway is also available to existing providers who are relevant providers on 1 January 2026.

[Schedule 5, item 10, section 1684A of the Corporations Act]

5.19 These amendments to the alternative qualification pathway for existing providers do not affect the existing transitional arrangements for the experienced provider pathway (section 1684AA of the Corporations Act).

Transitional arrangements for the majority of existing providers

5.20 The transitional arrangements outlined in new subsections 1684A(2) and 1684A(3), and described below, apply to existing providers except for those who did not pass the exam by their exam cut off day (either 1 January 2022 or 1 October 2022) and remained authorised as a relevant provider at the start of that day.

5.21 New subsection 1684A(2) provides that, before 1 January 2026, existing providers are not required to meet the qualifications standard in subsection 921B(2) and hence are not subject to civil penalties under section 921BA. This enables those existing providers to continue to provide personal advice to retail clients, subject to having passed the exam, while they undertake additional studies (as necessary). This reflects the existing transitional arrangements for existing providers.

[Schedule 5, item 1, subsection 1684A(2) of the Corporations Act]

5.22 From 1 January 2026 onwards, the qualifications standard applies to all existing providers. This means existing providers cannot continue to provide personal advice to retail clients on or after 1 January 2026, unless they have completed the necessary studies (or are relying on the experienced provider pathway in section 1684AA). This reflects the existing transitional arrangements for existing providers.

5.23 New subsection 1684A(3) provides that, from 1 January 2026 onwards, existing providers can satisfy their obligation (under subsection 921BA(1)) to meet the qualifications standard in 921B(2) via one of the following pathways:

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by completing a bachelor or higher degree approved by the Minister under section 921B; or

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by completing one or more 'top up' courses which the Minister has determined under section 1684E as giving an existing provider equivalent qualifications.

[Schedule 5, item 1, subsection 1684A(3) of the Corporations Act]

5.24 If an existing provider is a relevant provider on 1 January 2026, they must have completed the necessary studies (via either pathway) by 31 December 2025. Otherwise, they must cease providing personal advice to retail clients from 1 January 2026 onwards.

5.25 This corrects the inadvertent error in the current law which allows only one way for an existing provider who is a relevant provider on 1 January 2026 to meet the qualifications standard, which is to complete a bachelor or higher degree approved by the Minister.

[Schedule 5, item 1, paragraph 1684A(3)(b)(i) of the Corporations Act]

5.26 If an existing provider is not a relevant provider on 1 January 2026, they must have completed the necessary studies (via either pathway) before the day on which they next become a relevant provider. That is, after 1 January 2026, these existing advisers can only return as a relevant provider after they have completed the necessary studies. These existing providers remain exempt from the professional year requirement in 921BA(3). This reflects the existing transitional arrangements for existing providers.

[Schedule 5, item 1, paragraph 1684A(3)(b)(ii) of the Corporations Act]

5.27 From 1 January 2026, if an existing provider remains authorised as a relevant provider at the start of that day, but has not completed the necessary studies (via either pathway) then the option to complete one or more 'top up' courses determined by the Minister under 1684E is not available to them. If that person wants to return as a relevant provider on or after 1 January 2026, they would need to meet the same education and training standards as a new entrant to the industry. That is subject to having passed the exam they must:

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complete a bachelor or higher degree approved by the Minister (the first standard: subsection 921B(2)); and

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undertake a year of work and training, known as the 'professional year' (the third standard: subsection 921B(4)).

5.28 These amendments correct the inadvertent error in the current law (outlined in paragraph 1.17) to reinstate the original operation of the transitional arrangements for existing providers from the Corporations Amendment (Professional Standards of Financial Advisers) Act.

5.29 Following these amendments, if an existing provider had not passed the exam by the exam cut-off day and was not a relevant provider on the exam cut off day, they may return as a relevant provider only after they pass the exam. The qualifications standard applies from 1 January 2026 in line with the transitional arrangements in new subsections 1684A(2) and 1684A(3) (see paragraphs 1.20 to 1.23).

Consequences of failing to pass the exam

5.30 If an existing provider remained authorised as a relevant provider at the start of their exam cut off day without having passed the exam, the transitional arrangements for the qualifications standard contained in new subsections 1684A(2) and 1684A(3) do not apply. If that person wants to return as a relevant provider after the exam cut-off day, they need to meet the same education and training standards as a new entrant to the industry. That is, they must first:

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complete a bachelor or higher degree approved by the Minister (the first standard: subsection 921B(2)); and

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pass the exam (the second standard: subsection 921B(3)); and

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undertake a year of work and training, known as the 'professional year' (the third standard: subsection 921B(4)).

[Schedule 5 item 1, subsections 1684A(4) and 1684A(5) of the Corporations Act]

5.31 The amendments in subsections 1684A(4) and 1684A(5) have retrospective operation, since they apply from the exam cut off day (either 1 January 2022 or 1 October 2022). The amended provision replicates the existing arrangements for this cohort of existing providers, as outlined in the Financial Sector Reform (Hayne Royal Commission Response—Better Advice) Act 2021, which set out the consequences for existing providers of failing to pass the exam by the exam cut off day (either 1 January 2022 or 1 October 2022) and failing to meet the qualifications standard by the end of the transitional period (1 January 2026). Retrospective operation is appropriate in this case for continuity with the current transitional arrangements and to ensure that existing providers who were in breach of their obligation to have met the exam standard by the exam cut-off day do not benefit from a more flexible "top up" courses pathway to meet the qualifications standard.

[Schedule 5 item 1, subsections 1684A(4) and 1684A(5) of the Corporations Act]

Diagram 5.1 When do the transitional arrangements for the qualification standard apply?

Diagram 5.2 How to meet the qualifications standards under the transitional arrangements

5.32 Item 2 makes a consequential amendment to paragraph 1684E(1)(a).

[Schedule 5 item 2, paragraph 1684E(1)(a) of the Corporations Act]

5.33 Item 3 removes a reference to a repealed provision.

[Schedule 5 item 3, paragraph 1684E(1)(d) of the Corporations Act]

5.34 Item 4 ensures that the amendments to subsection 1684E(1) do not affect any determinations that have already been made by the Minister under that subsection.

[Schedule 5 item 4, subsection 1684E(3) of the Corporations Act]

Division 2—Foreign investment notices and applications

5.35 Division 2 of Schedule 5 to the Bill amends the FATA to address unintended practices by some users of the new Foreign Investment Portal.

5.36 Section 135 of the FATA requires a notice given, or application made, for the purposes of FATA to be made in the manner approved, in writing, by the Secretary.

5.37 The Government has launched a new Foreign Investment Portal as part of its foreign investment digital transformation project. Beginning on 28 May 2025, users must use the new portal to complete and submit their investment proposals.

5.38 An issue has emerged where some users have inserted entries like "see cover letter" into fields intended for the collection of discrete data and automated processes. Another example is entering zero into a monetary value field and relying on a cover letter to explain the true amount.

5.39 These practices interfere with the intended operation of the new portal and would significantly undermine the benefits of the foreign investment digital transformation project if not addressed.

5.40 The amendments empower the Secretary to approve the form as well as the manner in which a notice may be given or an application may be made. The reference to both manner and form is intended to maximise the Secretary's ability to determine the specifics of the portal and how applicants must use it. It provides clarity on the intended manner and form of use of the Foreign Investment Portal.

5.41 The amendments also use the words 'if any' to introduce some flexibility to ensure that there does not need to be an approved manner and an approved form at all times.

[Schedule 5 item 11, subsection 135(1) of the Foreign Acquisitions and Takeovers Act 1975]

5.42 The amendments also include consequential amendments to a heading, to a simplified outline and to various notes, as well as a clarification that an approved form may be an electronic form.

[Schedule 5 items 1 to 10 and 12 to 14, notes to subsections 57(1), 58(1), 59(1), 62(2), 76(6), 79Q(1) and 81(2), note to section 114, paragraph 131(e), heading to section 135, note to subsection 135(1), subsection 135(2) and note to subsection 135(4) of the Foreign Acquisitions and Takeovers Act 1975]

5.43 Additionally, the amendments expressly require strict compliance. This displaces any legal presumption that substantial compliance with a prescribed form is sufficient.

5.44 However, the amendments also introduce a mechanism for the Secretary to accept a particular notice or application if satisfied the notice or application is substantially compliant, and it is appropriate in the circumstances to treat it as being effective for the purposes of the FATA.

[Schedule 5 item 13, subsection 135(2A) of the Foreign Acquisitions and Takeovers Act 1975]

5.45 In summary, these changes are intended to allow for control over the information that users must enter into each particular field on the portal, to address unintended practices that have emerged.

5.46 The exercise of the Secretary's power to accept a substantially compliant notice or application is not subject to merits review. This power is intended to be used on a very limited and exceptional basis to deal with any unintended consequences of requiring strict compliance. It would generally be relatively easy for an applicant to resubmit a notice or application through the portal where they have fallen short of strict compliance. Given this, and the costs associated with providing for merits review of such a decision, the cost of merits review would be vastly disproportionate to the significance of the decision under review.

5.47 These amendments commence on the day after Royal Assent and apply in relation to a notice given, or an application made, on or after that day.

[Schedule 5 item 15]

Division 3—National Rental Affordability Scheme administration

5.48 Division 3 of Schedule 5 to the Bill ensures that the DSS can continue to make decisions to administer the NRAS.

5.49 The AAO issued on 13 May 2025 transferred the NRAS Act from the Social Services portfolio to the Treasury portfolio.

5.50 Section 11 of that NRAS Act concerns delegations and includes a reference to delegates 'in the Department'. There are also numerous references in that Act to 'the Secretary', in turn defined as 'the Secretary of the Department'.

5.51 Section 19A of the Acts Interpretation Act 1901 provides that a reference to a 'Department' is determined using the AAO, which now identifies Treasury as responsible.

5.52 While Treasury is taking carriage of policy responsibility for the NRAS Act pursuant to the AAO, it is necessary for the DSS to continue exercising the Scheme's administrative functions.

5.53 The amendments define 'Secretary' for the purposes of the NRAS Act to mean the Secretary of the DSS or the Secretary of the Treasury. This ensures that either Secretary can exercise the powers and functions that the NRAS Act confers on 'the Secretary'.

[Schedule 5 item 1, section 4 of the National Rental Affordability Scheme Act 2008]

5.54 In turn, the delegation powers in the NRAS Act are amended to empower either Secretary to delegate to employees of either Department.

[Schedule 5 items 3 and 4, subsections 11(1) and (2) of the National Rental Affordability Scheme Act 2008]

5.55 The amendments also add definitions to identify the two Departments for the purposes of the NRAS Act.

[Schedule 5 item 2, section 4 of the National Rental Affordability Scheme Act 2008]

5.56 While the amendments empower both Departments to exercise the administrative functions, in practice, the DSS is expected to continue to exercise the functions in its role as service provider, in close consultation with Treasury who will retain policy responsibility for the program as set out in the AAO.

Division 4—Notification of acquisitions

5.57 Division 4 of Part 1 of Schedule 5 to the Bill amends the CCA to:

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clarify when acquisitions are required to be notified under the new mergers review framework, and

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clarify that the Minister may determine, by legislative instrument, acquisitions that occur in circumstances, and classes of acquisitions, that are not required to be notified.

Legislative references in this section are to the CCA unless otherwise stated.

5.58 The new mergers review framework was recently incorporated into the CCA by the Treasury Laws Amendment (Mergers and Acquisitions Reform) Act 2024. Division 2 of Part IVA of the new mergers review framework sets out when acquisitions are required to be notified.

5.59 Prior to the amendments in this Bill, subsection 189(1) provided that Division 2 of Part IVA applied in relation to an acquisition that was put into effect on or after 1 January 2026, other than an acquisition to which subsection 189(2) applied. Under Division 2 of Part IVA, section 51ABO also provided, in general terms, that an acquisition was required to be notified if it occurred in circumstances determined by the Minister by legislative instrument under subsection 51ABP(1), or it was in a class of acquisitions determined by the Minister by legislative instrument under subsection 51ABQ(1).

5.60 This approach created some minor confusion regarding when an acquisition was required to be notified. This was an unintended outcome.

5.61 To clarify when an acquisition is required to be notified, the amendments repeal and replace both section 51ABO and subsection 189(1).

5.62 New section 51ABO expands on the previous version of section 51ABO (as set out in paragraph 1.58), to clarify that an acquisition is required to be notified if:

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the acquisition is put into effect on or after 1 January 2026; and

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the acquisition occurs in circumstances, or is in a class of acquisition, determined by the Minister by legislative instrument under subsections 51ABP(1) or 51ABQ(1) respectively, and

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the acquisition does not occur in circumstances, or is not in a class of acquisitions, determined by the Minister by legislative instrument under subsections 51ABRA(1) or 51ABRB(1) respectively.

[Schedule 5, item 1, section 51ABO of the CCA]

5.63 New subsection 189(1) no longer provides that Division 2 of Part IVA applies to an acquisition put into effect on or after 1 January 2026. The reference to 1 January 2026 is also removed from the heading to section 189. This is appropriate as the requirement to notify of an acquisition that takes effect on or after 1 January 2026 is now dealt with in new section 51ABO. However, new subsection 189(1) continues to provide that Division 2 of Part IVA does not apply in relation to an acquisition to which subsection 189(2) applies (that is, an acquisition in relation to which the ACCC has granted a merger authorisation, or has given written advice that they do not intend to take action under section 50, during the transitional period between 1 July 2025 and 31 December 2025).

[Schedule 5, items 8 and 9, section 189 (heading) and subsection 189(1) of the CCA]

5.64 The amendments also clarify that the Minister may determine, by legislative instrument, acquisitions that occur in circumstances, and classes of acquisitions, that are not required to be notified.

5.65 Specifically, new subsection 51ABRA(1) provides that the Minister may determine, by legislative instrument, circumstances in which acquisitions are not required to be notified for the purpose of new subparagraph 51ABO(c)(i). Without limiting this power, the Minister may determine circumstances that existed to any extent, or that relate to something that occurred, before 1 January 2026.

5.66 New subsection 51ABRB(1) provides that the Minister may determine, by legislative instrument, a class of acquisitions that are not required to be notified for the purpose of new subparagraph 51ABO(c)(ii). Without limiting this power, the Minister may determine a class of acquisitions wholly or partly by reference to:

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a party, or a class of parties, to an acquisition or to a contract, arrangement or understanding;

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an asset or a class of assets;

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a business or a class of businesses;

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a market or a class of markets;

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an industry or class of industries, or

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another acquisition or class of acquisition.

5.67 To avoid doubt, an instrument made under subsections 51ABRA(1) or 51ABRB(1) does not affect the meaning of substantially lessening competition.

[Schedule 5, item 6, sections 51ABRA and 51ABRB of the CCA]

5.68 New subsections 51ABRA(1) and 51ABRB(1) complement the Minister's existing statutory power to determine acquisitions that occur in certain circumstances, or classes of acquisition, that are required to be notified under subsections 51ABP(1) and 51ABQ(1) respectively.

5.69 Previously, subsections 51ABP(1) and 51ABQ(1), the reference to 'wholly or partly' in subsections 51ABP(2) and 51ABQ(2), and subsection 33(3A) of the Acts Interpretation Act 1901 provided the basis for the Minister to determine acquisitions that occur in circumstances, and classes of acquisitions, that were not required to be notified. New subsections 51ABRA(1) and ABRB(1) merely clarify this existing power.

5.70 It is appropriate for the Minister to be empowered to make a legislative instrument under subsections 51ABRA(1) and 51ABRB(1) as the scope of acquisitions that are not required to be notified may need to be adjusted based on emerging issues over time. For example, adjustments may be necessary to ensure that notification requirements are appropriately targeted at acquisitions that could pose a risk to competition.

5.71 Further, the Minister's power under subsections 51ABRA(1) and 51ABRB(1) will not be delegable. As an instrument made under subsections 51ABRA(1) and 51ABRB(1) will be a legislative instrument, it will be subject to disallowance, parliamentary scrutiny and sunsetting in accordance with the Legislation Act 2003. In addition, before making an instrument, the Minister must be satisfied that there has been appropriate and reasonably practicable consultation in accordance with section 17 of the Legislation Act 2003, including relevant consultation with the ACCC.

[Schedule 5, item 7, subsection 51ABZZS(2) of the CCA]

5.72 The amendments update several section headings to clarify that relevant sections apply in relation to acquisitions that are required to be notified.

[Schedule 5, items 3 and 5, sections 51ABQ and 51ABR (headings) of CCA]

5.73 A number of consequential amendments update references in subsections 51ABP(1) and 51ABQ(1).

[Schedule 5, items 2 and 4, subsections 51ABP(1) and 51ABQ(1) of the CCA]

Part 2 – Amendments with other commencement: Director penalty notices

5.74 Division 269 of the TAA sets out the director penalty framework, which may be used to hold a current or former director of a company personally liable for the company's unpaid tax and superannuation liabilities. Before commencing proceedings to recover these amounts, the Commissioner must issue a director penalty notice.

5.75 Since 1 July 2024, section 269-50 of the TAA provides that the Commissioner may issue a director penalty notice by leaving it at, or posting it to, an address that appears to be the director's place of residence or business. The director's place of residence or business is based on information held by the Registrar.

5.76 Item 1 amends this provision so that in issuing a director penalty notice, the Commissioner can rely on address information held by ASIC, instead of the Registrar. This amendment commences retrospectively on 1 July 2024.

[Schedule 5, item 1, section 269-50 of the Taxation Administration Act]

5.77 This item reverses an amendment made by item 142 of Schedule 4 to the Treasury Laws Amendment (2020 Measures No. 6) Act 2020, which replaced the original reference to ASIC in section 269-50 of the Taxation Administration Act with a reference to the Registrar. This amendment formed part of the legislative framework designed to support the former Modernising Business Registers program, where it was intended that the Registrar would hold the relevant information instead of ASIC. However, in August 2023, the Government announced it had ceased the former Modernising Business Registers program. As a result, ASIC remains responsible for holding the relevant address information of directors.

5.78 Further, under the former Modernising Business Registers program, the current amendments should have commenced on 1 July 2026, consistent with most of the other elements of that framework. However, the legislation contained an error, and the amendment instead commenced on 1 July 2024.

5.79 The retrospective commencement of item 1 therefore ensures that section 269-50 of the TAA operates as intended in an uninterrupted manner and is consistent with the way the Commissioner currently administers the director penalty framework. The amendment ensures that a director penalty notice issued by the Commissioner on and after 1 July 2024 to a director at an address that appears from information held by ASIC to have been the director's place of residence or business, is valid and effective for all purposes. The amendment does not have a direct impact on individuals as it only clarifies an administrative element of the director penalty framework. It also does not retrospectively impose any tax-related liabilities on an individual.

Commencement, application, and transitional provisions

5.80 Part 1 of Schedule 5 to the Bill commences on the day after Royal Assent.

5.81 Part 2 of Schedule 5 to the Bill commences immediately after the commencement of item 142 of Schedule 4 to the Treasury Laws Amendment (2020 Measures No. 6) Act 2020, being 1 July 2024.