It is an exciting time to be in tax with 2024 continuing the trend of significant and ongoing developments in the global and Australian international taxation framework.
On the global front, developments in the approach to Pillar 2 continues as we move closer to implementation by countries. On the Australian domestic front, the developments in the international taxation framework have never been more important as we deal with new policies and legislation on thin capitalisation and debt creation, intangibles and transparency measures.
We also have new ATO guidance on software and royalties and new ATO approaches to dealing with collateral issues as part of the APA program. And we have new judicial guidance on characterisation of payments and the diverted profits tax. We also continue to see the ATO focus on key international tax risks, including expanding its focus on hybrid mismatches.
This masterclass program was a must for anyone seeking to deepen their understanding of the international tax framework and learn more about the most important issues facing the industry. The sessions provided in-depth technical views and much needed practical insights. The program also delivered a variety of perspectives to ensure attendees heard from the leading experts including views from the ATO, leading advisers and expert barristers.