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ARTICLE · 22 OCTOBER 2026

Spotlight On The Australian Tax Landscape: Three Recent Developments

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The Australian tax landscape is undergoing significant transformation in 2026, with three major developments reshaping obligations for international investors and multinational entities.

AustraliaTax
Angelina Lagana
Angelina Lagana
Rhys Jewell
Rhys Jewell
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The Australian tax landscape is never static. Recent legislative changes and judicial authority continue to present challenges for taxpayers and advisers alike. Three developments in 2026 stand out for their broad reach and practical significance to taxpayers, particularly international investors, and multinational entities generally. This spotlight briefing distils the key points: what has changed, what it means, and what to look out for. 

Cross-border software payments: the expansion of royalty 

The Australian Taxation Office (ATO) recently released its long awaited final ruling in respect of software payments. It means that many common cross-border arrangements may now be considered to include a royalty component, with the flow on impact that such payment could  be subject to Australian royalty withholding tax with exposure dating back to July 2021. The Australian approach to software royalties is among the most expansive globally, diverging from positions taken by major

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