Insight
Gearing up for a new era of negative gearing: What investors need to know now
The 2026-27 Federal Budget delivered a tax reform trio that is reshaping the investment landscape: changes to negative gearing, a return to CGT indexation (see CGT amendments: A blast from the past and a new minimum tax), and a minimum tax on discretionary trust distributions (see Discretionary Trusts - Limited time offer for relief from minimum tax). This alert unpacks the negative gearing reforms, which have now become law with the Treasury Laws Amendment (Tax Reform No. 1) Act 2026 (the Act).
18 September 2026
Insight
Part IVA checks in: Commissioner prevails in Hilton hotel sale
The Federal Court has dismissed the taxpayer’s appeal in Hilton International Australia Pty Ltd v Commissioner of Taxation (No 2) [2026] FCA 1325 (Hilton), upholding the Commissioner of Taxation’s (Commissioner) application of the general anti-avoidance rule in Part IVA of the Income Tax Assessment Act 1936 (Cth) to the sale of the Sydney Hilton Hotel.
16 September 2026
Insight
Same game, new rules? ATO finalises software royalty ruling with PepsiCo in the mix
The finalisation of TR 2026/2 and the release of PCG 2026/D4 represent a significant moment for businesses with cross-border software distribution arrangements.
09 September 2026