Multinational tax integrity package


As part of the October 2022‑23 Budget, the Government announced a Multinational Tax Integrity Package, which would:

  • strengthen Australia’s thin capitalisation rules to address risks to the corporate tax base arising from the use of excessive debt deductions;
  • introduce an anti‑avoidance rule to deny deductions for payments made to related parties in relation to intangible assets connected with low‑ or no‑tax jurisdictions; and
  • introduce reporting requirements for relevant companies to enhance the tax information they disclose to the public.

Consultation outcomes

Stakeholders have been consulted throughout the development of the measures to inform their design and implementation.

A summary of the outcomes of the public consultation processes on exposure draft legislation for the measures is available.

Summary of outcomes - PDF 165KB

Summary of outcomes - DOCX 136KB

Deductions for payments relating to intangible assets connected with low corporate tax jurisdictions

The Government has made changes to better achieve the policy intent.

These changes are reflected in a revised Bill and explanatory memorandum. These are available below to provide stakeholders with certainty:

Exposure Draft Bill - PDF 250KB

Exposure Draft Bill - DOCX 128KB

Explanatory Materials - PDF 312KB

Explanatory Materials - DOCX 112KB

The Government is further considering interactions of the intangibles measure with global minimum taxes and domestic minimum taxes.

The Government announced Australia’s implementation of a 15 per cent global minimum tax and domestic minimum tax in the 2023‑24 Budget, joining a growing number of jurisdictions implementing a global minimum tax from 2024.

Related consultations