Expanding into Australia Is Still Attractive, but Structuring Has Become Riskier

australia-expansion-risks-intercompany-debt-and-thin-cap-rules

Australia remains a compelling expansion market. It offers political stability, a sophisticated financial system, strong IP protections, and access to the Asia-Pacific region. For years, foreign groups entering Australia relied on familiar playbooks: intercompany loans, centralized treasury models, and post-entry restructures to optimize funding and tax outcomes. That playbook is now under pressure. Recent changes … Read more

OECD Pillar Two Is No Longer Just “Tax Math”

oecd-pillar-two-global-minimum-tax

When the OECD’s Pillar Two global minimum tax was first announced, many multinational groups treated it as a future technical exercise: complex, yes, but largely a question of effective tax rate calculations, safe harbors, and spreadsheet-heavy modeling. That framing is now incomplete. Pillar Two is live, spreading through domestic legislation, administrative guidance, and country-by-country implementation. … Read more