Tax Bites: Insights on tax developments

We explore the latest tax developments. In this podcast series, our tax team delve into the latest developments that are likely to affect businesses functioning or actively trading.

Tax Bites: Insights on tax developments is a business podcast hosted by Herbert Smith Freehills Kramer, with 22 episodes on record and a Required Pod Score of 80. PitchCentric scores this show on Booking Probability, Listen Score, and live audience signals refreshed every 24 hours.

Herbert Smith Freehills Kramer hosts Tax Bites: Insights on tax developments, a business show with 22 episodes published.

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  Episode #22

  Tax Bites EP22: 2026 Federal Budget - CGT Discount Replaced, Negative Gearing Curtailed, and Discretionary Trusts Hit with Minimum Tax

  May 12, 202623 minS0

  <p>Late on Budget night Toby Eggleston, Ryan Leslie and Nick Heggart discuss Treasurer Chalmers’ budget, focused on reshaping personal tax, especially capital gains and discretionary trusts, under “intergenerational equity.” </p><p>Corporate measures are smaller, including re-announced non-resident CGT changes with intended retrospectivity to 2006 and limited transitional relief for renewables to 30 June 2030, expanded VCLP/ESVCLP investment caps, and R&D offset tweaks forecast to reduce tax by $1.5b. Small business changes include making the instant asset write-off permanent, a refundable loss offset for startups from 1 July 2028, and a permanent loss carry-back for companies under $1b turnover. </p><p>Major personal...

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  Episode #21

  Tax Bites EP21: Exposure Draft Shock: Expanded Non Resident CGT on Land-Connected Assets and Treaty Override

  Apr 20, 202635 minS0

  <p>Partners Toby Eggleston, Nick Heggart and Ryan Leslie discuss Treasury’s 10 April 2026 exposure draft legislation implementing and expanding the 2024 budget proposals on when non-residents pay Australian CGT. The draft materially broadens “taxable Australian real property” beyond general law real property (post the YTL and Newmont decisions) to include rights over land, contractual rights, and fixed or installed assets expected to be on land for most of their useful life (e.g., wind/solar assets, pipelines, mining equipment, tenant fixtures), plus water entitlements, with some elements proposed to apply retrospectively to 12 December 2006. It also includes a treaty-override via the International Tax Ag...

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  Episode #20

  Tax Bites EP20: Taxation of Earnouts and Contingent Consideration in M&A: TOFA, Look-Through Earnout Rules and Key Traps

  Mar 30, 202625 minS0

  <p>Toby Eggleston and Naison Seery discuss Australian tax treatment of earnouts and contingent consideration in M&A, noting increased use to bridge valuation gaps and that outcomes depend on TOFA, deal terms, metrics and payment timing, with ATO views still being tested. They outline the ATO’s shifting historical positions on whether earnout rights are separate CGT assets, buyer cost base treatment, and potential CGT event D1 exposure. TOFA is a key starting point for large taxpayers and can apply to contingent rights as financial arrangements, with timing and character mismatch implications; a business sale exception may exclude earnouts co...

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  Episode #19

  Tax Bites EP19: ATO focus on s128F, CGT rollovers, thin cap review and FIRB tax conditions

  Feb 17, 202618 minS0

  <p>Toby Eggleston, Ryan Leslie and Jay Prasad discuss recent Australian tax developments: the ATO’s targeted consultation and planned updated guidance on the s128F public offer interest withholding tax exemption; anticipated ATO guidance (now indicated for early 2026) on back-to-back CGT rollovers and potential Part IVA risk; the Treasurer’s request for a Board of Tax review of thin capitalisation reforms; and evolving FIRB tax conditions.</p><p>00:10 Welcome to Tax Bites & today’s agenda<br/>00:32 ATO consultation: Section 128F public offer IWT exemption (what’s changing)<br/>02:06 128F in practice: private credit complexity & evidence you’ll need<br/>03:53 Key takeaw...

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  Episode #18

  Tax Bites EP18: Dissecting the Full Federal Court's Decision in Commissioner of Taxation and Hicks

  Dec 29, 202526 minS0

  <p>In this episode of the Herbert Smith Freehills Kramer Tax Podcast, Tax Bites, partner Toby Eggleston, Associate Dan Beratis, and Ryan Leslie delve into the Full Federal Court's decision in the Commissioner of Taxation v Hicks case. <br/><br/>They discuss the background, facts, and history of the case, which involved a fashion retail business named City Beach, its restructure, and the tax implications under Section 45B and Part IVA of the 1936 Act. The episode covers the court's reasoning, the taxpayer's and commissioner's arguments, and key takeaways from the case, including the interpretation of Section 45B, the role of p...

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