Application Period

From the first day of the quarter following Royal Assent until 30 June 2030

As part of the 2026–27 Federal Budget, the Government announced further reforms to Australia’s foreign resident capital gains tax (CGT) regime, including transitional concessions aimed at supporting investment in renewable energy infrastructure.

The reforms form part of the Government’s earlier 2024–25 Budget measure designed to strengthen the taxation of foreign residents disposing of assets closely connected to Australian land and natural resources.

Under the transitional arrangements, eligible foreign investors disposing of qualifying renewable energy infrastructure assets will receive concessional CGT treatment until 30 June 2030.

The Government also confirmed that the meaning of “real property” for Australian CGT purposes will be determined solely under Commonwealth legislation rather than state and territory laws. This clarification will apply retrospectively from 12 December 2006, when the foreign resident CGT regime first commenced.

In April 2026, draft legislation was released proposing:

• a broader and clearer definition of taxable Australian real property (TARP); and
• a 50% CGT discount for foreign residents disposing of eligible Australian renewable energy assets.

2026–27 Federal Budget – Global Anti-Base Erosion Rules (Pillar Two)

Start Date

From 1 January 2026

The Government announced amendments to Australia’s Global Anti-Base Erosion (GloBE) rules to implement the OECD/G20 side-by-side package agreed on 5 January 2026.

The reforms are intended to ensure Australia’s global and domestic minimum tax rules remain aligned with international standards and other participating jurisdictions.

Under the existing GloBE framework, multinational groups with annual global revenue of at least EUR 750 million are subject to a minimum effective tax rate of 15% in each jurisdiction in which they operate.

The Government stated that the reforms will strengthen the integrity of Australia’s corporate tax base while ensuring large multinational enterprises pay an appropriate minimum level of tax globally.

Other Measures

2026–27 Federal Budget – Temporary Reduction of Fuel Excise

Application Period

Three months from 1 April 2026

Ahead of the 2026–27 Federal Budget, the Government announced temporary fuel tax relief measures aimed at easing cost-of-living pressures caused by rising fuel prices.

Fuel excise and excise-equivalent customs duty rates applying to most fuel products were temporarily reduced for three months from 1 April 2026.

The measure reduced fuel excise rates by approximately 60.9%, equivalent to around 32 cents per litre for petrol and diesel.

The heavy vehicle road user charge was also temporarily reduced from 32.4 cents per litre to zero.

State and territory governments agreed to contribute up to $400 million so additional GST revenue generated by higher fuel prices could be returned to consumers through lower fuel excise rates.

2026–27 Federal Budget – Extending the Ban on Foreign Purchases of Established Dwellings

Application Date

Extended until 30 June 2029

The Government announced that the temporary ban on foreign purchases of established residential dwellings will be extended for a further two years and three months until 30 June 2029.

Under the current rules, foreign persons, including temporary residents and foreign-owned companies, are generally prohibited from purchasing established residential properties in Australia unless limited exceptions apply.

Existing exceptions include:

• investments that significantly increase housing supply, such as new developments and vacant land; and
• purchases by foreign companies employing workers under the Pacific Australia Labour Mobility (PALM) scheme.

The Government stated that extending the restriction is intended to improve housing availability for Australians while continuing to encourage foreign investment in new housing supply.

Existing exemptions for permanent residents and New Zealand citizens will continue to apply.

2026–27 Federal Budget – Protecting the Tax System Against Fraud

Start Date

Over four years from 1 July 2026, with ongoing funding from the 2030–31 income year

The Government announced funding of $86.3 million over four years, together with ongoing annual funding of $9.7 million from 2030–31, to implement Phase 2 of the Counter Fraud Strategy.

The reforms are intended to modernise fraud prevention and detection across Australia’s tax and superannuation systems.

The Government will strengthen the Australian Taxation Office’s (ATO) powers to combat fraud involving tax agents and intermediaries, including:

• pausing debt recovery action for affected taxpayers;
• waiving tax debts in appropriate circumstances; and
• recovering liabilities directly from fraudulent intermediaries.

Additional reforms will include:

• expanded information-gathering powers for regulators;
• targeted exceptions to tax secrecy rules;
• broader garnishee powers covering jointly held assets; and
• further ATO compliance activities, including targeted reviews of Research and Development Tax Incentive claims.

The Government stated that the reforms are intended to strengthen tax system integrity, improve fraud detection, and provide greater protection for taxpayers.