Multinational tax integrity – denying deductions for payments relating to intangible assets connected with low corporate tax jurisdictions

This consultation process has now been completed. Submissions available
Consultation Type
Exposure Draft Legislation

Key Documents

As part of the 2022‑23 Budget, an anti‑avoidance measure to prevent large multinationals from claiming tax deductions for payments relating to intangibles connected with low corporate tax jurisdictions was announced. The measure forms part of the government’s commitment to ensure that multinational enterprises pay their fair share of tax in Australia to help fund vital services, repair the Budget and level the playing field for Australian businesses. 

The government has prepared exposure draft legislation to give effect to the measure. 

A previous consultation on this initiative, along with other multinational enterprise interest limitation (thin capitalisation) and transparency proposals, was held in August and September 2022.

The government is seeking stakeholders’ views on the exposure draft legislation and accompanying explanatory material implementing this measure.

Stakeholders’ views are also sought on priority issues that would inform the ATO's public advice and guidance on this measure.

The government is simultaneously consulting on the other elements of its multinational tax integrity package as separate measures, with consultation occurring on interest limitation (thin capitalisation) rules, and disclosure of subsidiary information. Consultation on the public country‑by‑country measure will commence shortly.


28 submissions were received for this consultation, including 3 confidential submissions.


1 submission was received for this consultation.