In this edition of Andersen in Australia’s Monthly Tax Update, we provide recent legislative updates and outline the latest developments in the areas of corporate tax, individual tax, indirect tax and international tax. We also examine the ATO’s recent activities, publications, rulings and other guidelines and discuss the latest Australian tax cases.

Key Sections

Legislation Updates

Bills to Legislate Payday Super Received Royal Assent

The Superannuation Guarantee Charge Amendment Bill 2025 (Act No 58 of 2025) and the Treasury Laws Amendment (Payday Superannuation) Bill 2025 (Act No 57 of 2025) (the Bills) have received royal assent on 6 November 2025 and are now law.

Under the new payday superannuation guarantee (SG) system, employers who make SG contributions so that they reach an employee’s super fund within a specified period, typically seven business days after paying qualifying earnings, can reduce their SG charge liability to nil. Late or missing contributions will result in a SG shortfall, with notional earnings accruing to compensate the employee. First-time contributions to a fund receive additional time to comply.

The Treasury Laws Amendment (Payday Superannuation) Bill 2025 also include consequential amendments to other tax and superannuation legislation.

The Bills will commence on 1 July 2026, applying to superannuation guarantee contributions in respect of qualifying earnings days on or after 1 July 2026.

Bills to Legislate Payday Super Received Royal Assent

The ATO has also released draft guidance (PCG 2025/D5) outlining its proposed compliance approach for the first year of Payday Super, following the introduction of the Treasury Laws Amendment (Payday Superannuation) Bill 2025.

This Guideline outlines the ATO’s proposed compliance approach for the first year of operation of Payday Super, specifically regarding the investigation of superannuation guarantee (SG) shortfalls for a QE day (as defined in section 17A of the SGAA, as proposed to be amended) occurring between 1 July 2026 and 30 June 2027.

Consultation on the Guideline closed on 7 November 2025.

Small Business Superannuation Clearing House to Close Permanently

The Small Business Superannuation Clearing House (SBSCH), used by small businesses to process employee superannuation payments, will permanently close on 1 July 2026.

The ATO is urging small businesses that use the SBSCH to arrange an alternative method for paying superannuation guarantee (SG) contributions well before the closure. Businesses should ensure:

• They have a process in place to pay SG for the March and June 2026 quarters.
  
• They avoid late payments for the June 2026 quarter (due 28 July), as the SBSCH will be closed, and
  
• They finalise payments and download reports before the shutdown.

The ATO recommends checking existing payroll or accounting software, as many already include super payment features, or considering solutions from super funds, digital service providers, or commercial clearing houses.

The closure of the SBSCH coincides with the commencement of Payday Super on 1 July 2026.

Please refer here for further information.

Other Legislation Update

Administrative Review Tribunal Amendment Bill Passes House

The Administrative Review Tribunal and Other Legislation Amendment Bill 2025 (the Bill) has passed the House of Representatives. It amends the Administrative Review Tribunal Act 2024 to allow the Administrative Review Tribunal (ART) to decide cases without holding a hearing in certain circumstances.

The ART may do so when:

• The issues can be properly resolved without the parties present,
  
• It is reasonable to proceed this way, and
  
• Parties have had a fair chance to make submissions, which the ART has considered.

The aim is to give the ART greater procedural flexibility for straightforward cases while maintaining fairness and due process.

The amendments will apply to both new and ongoing applications where a decision has not yet been made once the Bill takes effect.

Bill Introduced to Retrospectively Authorise VSL Providers to Handle Student TFNs

VET Student Loans (Miscellaneous Measures) Bill 2025 (the Bill) has been introduced to retrospectively authorise approved VET Student Loans (VSL) providers to collect, use, and disclose students’ tax file numbers (TFNs) for the administration of the VSL program up to 1 October 2025.

The Bill seeks to retrospectively authorise approved VSL providers and relevant officials to handle students’ tax file numbers (TFNs) for administering the VSL program from its commencement on 1 January 2017 until 1 October 2025. The Bill validates past actions by providers, including requiring, collecting, recording, storing, using, and disclosing TFNs via the Electronic Commonwealth Assistance Form (eCAF) and Tertiary Collection of Student Information (TCSI) systems, as well as retrospective disclosure of TFNs by the Department of Employment and Workplace Relations.

These measures were necessary because VSL provider officers previously accessed TFNs to facilitate student participation, loan administration, and repayment reporting to the ATO, but system updates in 2025 masked TFNs and automated transfers to eliminate provider involvement.

The Bill is purely retrospective, ensuring that historical TFN handling is legally authorised for the limited purposes of administering VSLs, without permitting any future access or disclosure.

Tax Treatment of Foreign Bail-In Bonds Clarified

A new legislative instrument (F2025L01248) has been made to ensure consistent tax treatment for financial instruments issued by foreign regulated entities and APRA-regulated entities subject to non-viability conditions under the Basel III capital reforms.

The Income Tax Assessment (1997 Act) Amendment (Term Subordinated Note) Regulations 2025 amend the Income Tax Assessment (1997 Act) Regulations 2021 to extend the existing rule, which disregards the non-viability condition when testing whether an instrument qualifies as debt under s 974-20 of ITAA 1997 — to cover equivalent instruments issued by foreign-regulated entities.

This ensures such instruments are eligible for debt treatment if other requirements are met, preventing unintended tax outcomes from prudential capital rules.

The regulations commenced on 17 October 2025, with application from 12 December 2012.

Please refer here for further information.

Draft Legislative Instrument on PAYG Withholding Variation for Certain Insurance and Compensation Payments

The ATO has released a draft legislative instrument (LI 2025/D18) that sets the required withholding amount to nil for certain insurance and compensation payments made when a payee has not provided an ABN.

Normally, payers must withhold tax under section 12-190(1) of Schedule 1 to the Taxation Administration Act 1953 if a payee fails to quote their ABN. However, it can be uncertain whether this applies to payments made in settlement of insurance or compensation claims.

Under the new draft instrument, no withholding will be required for payments made:

• By an insurer settling a claim under an insurance policy;
  
• By an operator of a statutory compensation scheme settling a compensation claim; or
  
• By an operator of a compulsory third party scheme settling a compensation claim.

This change provides clarity, reduces compliance costs, and removes the need for payers to issue payment summaries for these transactions.

The new instrument repeals and replaces the existing PAYG Withholding Variation: Insurance and Compensation instrument, which was due to sunset on 1 April 2026.

It will commence the day after registration, and public comments are open until 28 November 2025.

Draft Legislative Instruments on GST Attribution Rules

The ATO has released three draft legislative instruments to continue existing GST attribution rules for specific types of supplies that are due to sunset on 1 April 2026. Each instrument updates and replaces an earlier version while maintaining the current practical outcomes for affected taxpayers.

• LI 2025/D19 – Motor Vehicle Incentive Payments.

This instrument modifies the GST attribution rules in Division 29 of the A New Tax System (Goods and Services Tax) Act 1999 for motor vehicle dealers who receive incentive payments from manufacturers, distributors, or importers.

It ensures that GST on a vehicle sale is attributed to the tax period in which the dealer knows the total consideration for the supply, even if part of it (the incentive) is determined later.

It repeals and replaces the 2015 instrument governing particular attribution rules for motor vehicle incentive payments.

• LI 2025/D20 – Prepayment of Telecommunication Supplies.

This instrument modifies attribution rules for telecommunication supplies when prepayments are made.

GST is attributable to the earlier of:

• The period when an invoice is issued, or
  
• The period when an invoice would have been issued had the prepayment not been made. This applies only to suppliers not accounting on a cash basis and replaces the 2016 determination for prepayments of telephone services.

• LI 2025/D21 – Supplies of Electricity Distribution Services

This instrument modifies attribution rules for electricity distribution services, ensuring GST and adjustments are attributed to the period when the supplier receives complete billing information from the billing agent to determine total consideration.

It applies where the supplier does not account on a cash basis, and the billing agent issues invoices for the supplies. It repeals and replaces the 2016 determination for electricity distribution services.

All three draft instruments will commence the day after registration on the Federal Register of Legislation, and public comments are open until 28 November 2025.

Draft GST Legislative Instrument on Supplies Relating to Fund-Raising Events

The ATO has released draft legislative instrument LI 2025/D22, which allows an endorsed charity, gift-deductible entity, or government school to treat all supplies made in connection with a fund-raising event as input taxed, provided it holds 15 or fewer similar fund-raising events in a prescribed accounting year.

Under section 40-160 of the A New Tax System (Goods and Services Tax) Act 1999, eligible entities can choose to treat supplies from a fund-raising event as input taxed. This means:

• The entity does not charge GST on supplies made in relation to the event; and
  
• It cannot claim input tax credits for related acquisitions.

However, if the entity holds 16 or more similar fund-raising events in a year, it cannot treat any of those supplies as input taxed and must remit GST on all such events (including the first 15).

The instrument commences the day after registration on the Federal Register of Legislation, and comments are open until 28 November 2025.

Draft WET Legislative Instrument on New Zealand Producer Rebate

The ATO has released a draft legislative instrument (LI 2025/D23) that permits eligible New Zealand wine producers exporting wine to Australia to access a producer rebate.

Under s 17-10(2A) of the A New Tax System (Wine Equalisation Tax) Act 1999 (the Act), eligible New Zealand wine producers may lodge a claim in Australia for a wine tax credit (producer rebate) in the approved form, provided they satisfy the entitlement conditions set out in s 19-5(2) of the Act.

Section 17-10(2B) of the Act authorises the Commissioner to determine, by legislative instrument, the time periods during which a claim for a wine tax credit for a producer rebate may be made. A special claim cycle is necessary for New Zealand participants that are not registered for GST, as their claims cannot be aligned with GST lodgment obligations in the same way as those of GST-registered entities.

LI 2025/D23 permits eligible New Zealand wine producers exporting wine to Australia to claim a producer rebate, in the form of a wine tax credit, at any time within four years after the credit arises. This measure aims to reduce compliance costs for New Zealand wine producers that are not registered for GST in Australia by providing greater flexibility in claiming their wine tax credits.

This instrument repeals and replaces the Wine Equalisation Tax New Zealand Producer Rebate Claim Lodgment Determination (No. 34) 2016, which is scheduled to sunset on 1 April 2026.

The new instrument will take effect on the day following its registration on the Federal Register of Legislation. Submissions on the draft instrument are open until 5 December 2025.

Draft Legislative Instrument on PAYG Withholding Variation – Individual Appointed as a Director

The ATO has released a draft legislative instrument (LI 2025/D24) proposing to vary the rate of withholding under the pay as you go (PAYG) system for certain payments made to individuals. The variation applies where the individual is required to remit the entire payment to another entity of which they are a director, partner, or employee.

Under LI 2025/D24, the withholding amount for such payments is reduced to nil. This applies when payments are made to an individual who serves as a director, committee member, or office holder, and who must pay the full amount received in that capacity to another entity (the second entity) where they hold a role as a director, partner, or employee.

The draft instrument also removes the requirement to issue payment summaries or report these payments through the Single Touch Payroll (STP) system.

This change is intended to prevent unnecessary withholding and reporting in cases where payments are, in effect, made to an entity rather than directly to an individual.

The instrument will repeal and replace the PAYG Withholding Variation: Company Directors and Office Holders (F2016L00222) (the 2016 instrument), which is due to sunset on 1 April 2026. While the new instrument largely maintains the same effect as the 2016 instrument, it introduces an additional exemption from STP reporting requirements, which were implemented after the 2016 instrument was made.

The instrument is scheduled to commence on the day following its registration on the Federal Register of Legislation. Submissions on the draft are open until 5 December 2025.

OECD Updates

OECD Secretary-General Tax Report

The OECD Secretary-General released a tax report ahead of the G20 Finance Ministers and Central Bank Governors Meeting on 15–16 October 2025.

The report outlines recent progress in international tax co-operation, including:

• Implementation of BEPS minimum standards;
  
• Advancement of the Two-Pillar Solution (BEPS 2.0) addressing digital economy taxation; and
  
• Enhancements to global tax transparency measures.

Annexures include:

• An Inclusive Framework stocktake on BEPS implementation and its decade-long impact; and
  
• A voluntary international framework for exchanging real estate ownership information.

The OECD also plans to release a future report on simplifying international tax rules.

For further information, please refer to the OECD website.

OECD Publishes Updated Transfer Pricing Country Profiles

The OECD has released an updated set of transfer pricing country profiles for 25 jurisdictions, expanding coverage to 83 countries in total. For the first time, the profiles include Cabo Verde, Guatemala, Thailand, the United Arab Emirates, and Zambia. The new edition introduces sections on the hard-to-value intangibles (HTVI) approach and the simplified and streamlined approach for baseline marketing and distribution activities, reflecting developments under Amount B of the OECD’s Two-Pillar Solution on global tax reform. A fourth and final batch of updated profiles is scheduled for December 2025.

For further information, please refer here.

OECD Released 2024 Statistics on Tax Disputes

The OECD has released its 2024 statistics on Mutual Agreement Procedures (MAPs) and Advance Pricing Arrangements (APAs) as part of the BEPS Action 14 Minimum Standard and the broader OECD/G20 tax certainty agenda to strengthen tax dispute resolution and prevention.

2024 MAP Statistics reveal the following:

• Average case resolution time remained stable at 27.4 months.
  
• Transfer pricing cases slightly improved at 30.9 months (down from 32 in 2023).
  
• Other cases improved at 24.5 months (up from 23.4).
  
• 76% of MAP cases reached full resolution (up from 74%), with only 4% closed without agreement.
  
• Authorities reduced aged cases: only 3.3% predate 2016, fewer than 20% are older than 4 years, and 56% are under 2 years old.

According to the 2024 APA Statistics:

• 80 jurisdictions now allow bilateral APAs (up from 73 in 2023); 49 actively manage them.
  
• Bilateral APA filings rose by 3%, with about 25% of inventory closed (steady from 2023).
  
• APAs make up 37.8% of bilateral transfer pricing caseloads on average, with 11 jurisdictions exceeding 50%.
  
• APAs granted fell by 2%, while rejections/closures without agreement rose to 19% (up from 12%).
  
• Average time to grant APAs increased to 39.6 months (up from 36.8).

The OECD also issued a preliminary 2025 update of the Consolidated Information on Mutual Agreement Procedures.

Together, these updates enhance transparency and support continued improvement of tax-related dispute resolution mechanisms.

For further information, please refer to the OECD website.

Other Updates / News

Consultation Opens on Amendments to Rules for Global and Domestic Minimum Tax Relating to OECD BEPS Pillar 2

Treasury has released draft legislation for consultation proposing amendments to Australia’s domestic framework for the multinational top-up tax, to reflect the latest Administrative Guidance issued by the Organisation for Economic Co-operation and Development (OECD).

The draft legislation, Taxation (Multinational—Global and Domestic Minimum Tax) Amendment (2025 Measures No.1) Rules 2025 would update the Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024, implementing the OECD’s 15% global and domestic minimum tax (Pillar Two). The amendments aim to align Australia’s rules with recent OECD administrative guidance and include:

• Clarifying when securitisation entities may be subject to undertaxed profits rule (UTPR) top-up tax,
  
• Introducing an equity investment inclusion election and rules for qualified flow-through tax benefits,
  
• Making minor adjustments to the domestic minimum tax (DMT) provisions, and
  
• Clarifying the investment entity transparency election for regulated mutual insurance companies.

The amendments are intended to apply retrospectively from 1 January 2024. Submission of comments due by 21 November 2025.

For further information, please refer here.

AUSTRAC Guidance for AML/CTF Regime Changes

AUSTRAC has released guidance to help current and future reporting entities comply with upcoming changes to Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) legislation.

From 1 July 2026, thousands of new businesses, including real estate agents, accountants, lawyers, and dealers in precious metals and stones will fall under the AML/CTF regime, with current reporting entities required to comply by 31 March 2026.

The guidance provides practical, cost-effective advice tailored to business size and complexity, including risk insights and indicators for newly regulated sectors, and additional support for digital currency exchanges. It also outlines changes affecting current reporting entities, with further sector-specific resources and AML/CTF program starter kits to be released by AUSTRAC in the future.

For further information, please refer here.

Tax Ombudsman Review on ATO’s Service to Agents

The Tax Ombudsman’s 2025 review found rising dissatisfaction among tax agents with the ATO’s service quality, particularly the registered agent phone line. The review revealed a strained relationship between the ATO and the agent community.

Key Findings:

• Rising agent dissatisfaction with ATO service and strained relationships.
  
• 65% of agents report issues using ATO online systems.
  
• Agents expect specialist phone support, but most calls go to inexperienced contractors.
  
• Phone service problems reflect broader engagement and system issues.

Main Recommendations:

• Strengthen engagement & recognition of agents’ vital role.
  
• Improve digital services – fix gaps in Online Services for Agents & practice mail.
  
• Enhance phone service quality – performance data, feedback, and routing to skilled staff.
  
• Simplify client-agent linking – clearer guidance and better support for taxpayers.

ATO accepted all but one recommendation.

Rejected routing calls to experienced staff, focusing instead on:

• Enhancing digital channels.
  
• Staff training & escalation improvements.
  
• Creating specialist teams for complex issues.

For further information, please refer here.

Cash Acceptance Draft Regulations

The Australian government is consulting on draft regulations that would require grocery and fuel retailers to accept cash for in-person transactions under $500, with an exemption for small businesses.

The exemption applies to businesses with aggregate turnover under $10 million, or, for franchise arrangements, where the franchise’s turnover is under $10 million. The draft regulations would establish new mandatory industry codes of conduct, with a government review planned after three years to assess whether the mandate should be expanded. Consultation on the draft regulations closes on 31 October 2025, and the proposed commencement date is 1 January 2026.

These proposals follow a July consultation paper from the Council of Financial Regulators and the ACCC on regulating cash distribution, which the government will consider carefully.

More information is available here.

ATO Rulings & Activity

Decision Impact Statement – A. AG v Federal Tax Administration

The ATO issued a Decision Impact Statement following a Swiss Federal Supreme Court ruling that upheld Switzerland’s obligation to provide information requested by the ATO under Article 25 of the Australia–Switzerland Tax Treaty. The request related to a transfer pricing audit of an Australian group purchasing stock from a Swiss supplier. The Court rejected the Swiss supplier’s argument that the information request breached Article 9 of the treaty, which concerns associated enterprises. The ATO views the decision as confirming that it can seek treaty-based information relevant to enforcing Subdiv 815-B (transfer pricing rules) even when the entities involved are not associated enterprises under the treaty.

Please refer here for further information.

Practice Statement on Advance Pricing Arrangements Updated

The ATO has updated Law Administration Practice Statement PS LA 2015/4 on advance pricing arrangements (APAs) to reflect the 2023 APA Program Review and process improvements.

The updates include clearer mutual expectations, revised program entry criteria, enhanced transparency and clarity in decision-making, governance updates, and guidance on handling collateral issues at different APA stages. The statement has also been revised to meet current ATO style and accessibility standards.

Minor Correction to Practice Statement on Cross-Border Tax Debt Recovery

A footnote in Practice Statement Law Administration PS LA 2011/13 (Cross-border recovery of taxation debts) referencing an OECD convention has been corrected.

Draft GST Determination on Supplies of Formula Products

The ATO has issued Draft GST Determination GSTD 2025/D1, clarifying when the supply of infant formula is GST-free under the GST Act.

The determination states that only formula products for children up to 12 months are GST-free, as they are considered “food for infants,” while formula for children over 12 months does not qualify. Additionally, formula products are not GST-free under other table items because they are not primarily milk or powdered milk.

The draft determination is open for comments until 28 November 2025, and once finalized, it will apply both retrospectively and going forward, with the Detailed Food List updated to reflect this view.

Draft Update to GST Ruling on Commercial Residential Premises

The ATO has released a draft update to GST Ruling  GSTR 2012/6 to clarify how GST applies to modern build-to-rent developments in relation to commercial residential premises. The ruling, which outlines how key provisions of the GST Act 1999 apply to supplies of commercial residential premises and accommodation, generally treats sales or leases of such premises as taxable supplies.

The draft update (GSTR 2012/6DC) adds an example of a build-to-rent development, confirming that these are typically input-taxed supplies of accommodation in residential premises under section 40-35(1)(a), rather than taxable supplies like hotels or motels. This reflects the more permanent nature of build-to-rent accommodation, where residents are tenants rather than guests. The update also provides further guidance on distinguishing hostels and the status of guests versus tenants to help determine correct GST treatment.

The ATO is inviting public comments until 19 December 2025.

ATO Guidance on Applying Pillar Two Transitional CBC Reporting Safe Harbour

The ATO has published the following online guidance on the application of the transitional country-by-country (CbC) reporting safe harbour under the OECD’s Base Erosion and Profit Shifting (BEPS) Pillar Two global and domestic minimum tax framework:

• Transitional CBC reporting safe harbour.
  
• Transitional CBC reporting safe harbour data.
  
• De minimis test.
  
• Simplified effective tax rate (ETR) test.
  
• Routine profits test.

The transitional country-by-country (CbC) reporting safe harbour is one of four safe harbours available to multinational enterprise (MNE) groups for determining their Australian top-up tax liability under the Australian Pillar Two rules.

An MNE group may elect to use this safe harbour only if it can demonstrate that it meets the de minimis test, simplified effective tax rate (ETR) test, or routine profits test for a given jurisdiction. These tests must be satisfied using the prescribed transitional CbC reporting safe harbour data.

When applied, the safe harbour effectively treats the MNE group’s jurisdictional top-up tax for that jurisdiction and fiscal year as zero, subject to certain exceptions.

The transitional CbC reporting safe harbour is limited to fiscal years beginning on or before 31 December 2026 and ending on or before 30 June 2028.

For further details, please refer to ATO website.

Offshore Merchant Data-Matching Program

The ATO has advised it will collect merchant data from the “big four” Australian banks for the 2024–25 to 2026–27 financial years to identify offshore businesses required to register and pay Australian GST.

Data to be collected includes offshore entity names and descriptors, merchant country, city, acquirer and category codes, contact details, transaction counts, total transaction values in AUD, and other currencies used. The information will help the ATO identify businesses supplying imported services, digital products, and low-value goods to Australian consumers, educate offshore entities on GST obligations, and support risk management strategies.

Approximately 9,000 offshore merchants’ records are expected to be obtained annually, with data sourced from ANZ, Commonwealth Bank, NAB, and Westpac.

For further information, please refer here.

Ruling on Effective Life of Depreciating Assets Withdrawn

The ATO has withdrawn Taxation Ruling TR 2022/1 on the effective life of depreciating assets, except for Tables A and B, which are now included in the Income Tax Assessment (Effective Life of Depreciating Assets) Determination 2025.

The guidance previously in the ruling has been reissued as ATO web content under “Using our determinations.” The Legislative Instrument, which lists effective life determinations for assets, is periodically updated and continues to apply despite the withdrawal of TR 2022/1.

For further information, please refer here.

Class Rulings Issued:

Latest Australian Tax Cases

> VZFS v FC of T [2025] ARTA 2013 – 7 October.
Tribunal confirmed GST liability on subdivided farmland sales, finding activities were commercial and part of an enterprise under GST Act ss 9-5(b), 9-20(1)(b).

> Merchant & Anor v FC of T [2025] FCAFC 56.
Full Federal Court upheld Part IVA and dividend stripping provisions applied to a share sale scheme; taxpayers failed on TOFA arguments. Special leave to appeal granted.

> G Global 120E T2 Pty Ltd & Ors v Commissioner of State Revenue (Qld); Stott v Cth & Anor [2025] HCA 39 – 15 October.
High Court validated amendments allowing state land tax surcharges on foreign-owned land from 2018; confirmed external affairs power and no property acquisition.

> Little Monster Productions Pty Ltd v Screen Australia [2025] ARTA 1732.
Tribunal disallowed $6.6m QAPE claim for producer offset; amount not incurred and excluded under s 376-135 ITAA 1997.

> Cavallaro & Ors v Tax Practitioners Board [2025] ARTA 2028.
Registrations terminated for repeated non-compliance and false declarations; ART reduced reapplication ban to one year due to contrition and remedial efforts.

> Safarimaznabi v FC of T [2025] FCA 1266 – 17 October.
Federal Court allowed whistleblower’s negligence claim against Commissioner to proceed, rejecting summary dismissal.

> YTL Power Investments Ltd v FC of T [2025] FCA 1317 – 30 October.
Court held s 855-10(1) applied to disregard $947m capital gain on ElectraNet shares; rejected Commissioner’s interpretation of Division 855.

> FC of T v ACN 154 520 199 Pty Ltd (in liq) [2025] FCAFC 146 – 24 Oct.
Full Court set aside AAT decision allowing $120m GST input tax credits on scrap gold; Division 165 anti-avoidance provisions may apply.

> Fraser v FC of T [2025] ARTA 2153 – 6 October.
Tribunal largely upheld denial of ITC claims for YouTube channel expenses; most purchases lacked business nexus.

> FC of T v Huang [2025] FCA 1314 – 24 October.
Federal Court overturned AAT decision on administrative penalties; taxpayer bore burden of proving assessments excessive.

> Urquhart v FC of T [2025] ARTA 2267 – 24 October.
Tribunal denied Dependant (Invalid and Carer) Tax Offset; legislative requirement for qualifying pension strictly applied.

> Oracle Corporation Australia Pty Ltd & Ors v FC of T [2025] FCAFC 145 – 21 October.
Full Court granted stay of proceedings to allow MAP under tax treaty; confirmed taxpayers’ right to treaty processes.

> XLZH v FC of T [2025] ARTA 2154 – 3 October.
Tribunal held trust shares retained pre-CGT status under Division 149; no taxable capital gain arose from 2019 sale.