This practical session explores the key tax challenges shaping cross-border M&A in an environment of heightened regulatory scrutiny and ongoing reform. Drawing on insights from recent transactions, the session will examine effective engagement with Australian regulators, including the Australian Taxation Office, the Australian Securities and Investments Commission and the Foreign Investment Review Board, and the implications of evolving guidance and enforcement activity for deal execution, restructures and divestments.
The session also considered current issues relating to taxable Australian real property, valuation approaches and recent case law developments, together with the impact of targeted ATO reviews and global tax reform initiatives such as Pillar Two on transaction due diligence. It concludes with observations on the renewed focus of revenue authorities on tax residency, treaty access, substance and beneficial ownership, and what this means in practice for structuring and managing risk after completion.