In the final Tax Briefing for 2025, hosted by Patricia Muscat, experts provided a forward-looking analysis of the tax and compliance landscape anticipated in 2026. The panel—Sarah Stevens (International Tax), Theo Denovan (Tax & Legal Chief Technology Officer), Trinh Hua (Infrastructure & Deals) and Angela Diec (Workforce)—covered major new compliance obligations, likely regulator focus areas, and how technology (including GenAI) can help teams manage the increasing burden.
Key compliance obligations on the horizon
Two new and significant compliance regimes will impact large taxpayers in 2026—public country-by-country (CBC) reporting and Pillar Two.
The first public CBC reporting lodgment deadline falls on 30 June 2026, for the 30 June 2025 year. The ATO has finalised guidance on exemptions, which will only be granted in exceptional cases. As such, most multinational groups will need to ensure they have robust systems to meet the reporting requirements. Entities should verify their in-scope status promptly, start assessing their data capture capabilities, and develop clear communication strategies concerning the public disclosure of potentially sensitive tax information.
Pillar Two global minimum tax filings are also due on 30 June 2026 for fiscal years ending 31 December 2024. Multinational groups will need to prepare and lodge the GLOBE information return and the combined global and domestic minimum tax return with the ATO on time to avoid penalties. Preparations should include early engagement across entities to assign responsibilities and validate transitional safe harbour qualification if seeking to rely on the simplified calculations.
Growing volume and complexity of disclosure obligations
The breadth and depth of tax return disclosures continue to expand substantially. Over two decades, the typical company tax return has grown from around 12 pages to over 44 pages, including supplementary schedules. For 2026, large superannuation funds and collective investment vehicles will face new requirements to complete the Reportable Tax Position schedule, adding further to reporting complexities. Tax teams are encouraged to plan for this increased demand, noting that the ATO is undertaking some limited rationalisation, which aims to apply a ‘provide it once’ principle to reduce duplication.
Technology as an enabler for compliance and productivity
Given the escalating compliance workload amidst already stretched tax teams, technology adoption is now indispensable. Core compliance technology tools, including tax provision calculators and filing engines, will facilitate meeting regulatory demands. Simultaneously, advancements in Generative AI (Gen AI) have embedded intelligence into everyday workflows such as drafting documents, conducting research, and responding to routine tasks, delivering significant productivity benefits.
Looking ahead to 2026, it is expected that Gen AI functionalities will be seamlessly integrated within existing software environments (e.g. ERP systems, Microsoft Office products), becoming an invisible yet essential element of tax professionals’ toolkits.
Workforce and employment matters
With the rollout of Payday Super reforms commencing 1 July 2026, employers must align superannuation contributions with employee salary payments, shifting from the current quarterly system to a more frequent (within seven business days) payment obligation. This change requires enhanced coordination among tax, finance, HR, and payroll teams, as well as early dialogue with payroll vendors and super clearing houses to ensure system readiness.
Proactive governance, risk management, and error handling protocols will be crucial for managing compliance risks. Secondary reconciliation systems feature prominently as tools to maintain timeliness and accuracy in the face of increasing data volumes.
Significant developments in employment-related legal cases, such as the landmark Federal Court decision concerning underpayment of salaried staff, underscore the importance of strict compliance with annualised salary provisions, comprehensive record-keeping, and employee consent for award variations. Organisations are advised to proactively strengthen payroll practices and documentation to mitigate potential liabilities.
Regulatory focus and tax reform outlook
The ATO will maintain its focus on international tax issues, including transfer pricing, related party financing, and private capital investment lifecycles. The ATO’s recent three-tier behavioral model highlights its data-driven approach to identifying compliance risks and targeting enforcement efforts.
Significant tax rulings and cases are expected to unfold in 2026, notably around long-term construction contracts, software royalties, and back-to-back CGT rollovers. The workforce regulatory environment will stay dynamic, with intensive scrutiny on payroll tax, superannuation compliance, and contract worker classifications, including high-profile cases like Uber’s appeal on payroll tax application to gig economy workers.
Despite ongoing dialogues on tax reform and red tape reduction, substantive changes are unlikely to materialise immediately. The Productivity Commission and the Board of Taxation are expected to release reports with bold proposals, such as corporate tax rate adjustments and simplified cash flow taxes, yet legislation enacting these remains uncertain and potentially distant.
Conclusion: Preparing for a transformative year
As 2026 approaches, taxpayers and advisors face a rapidly evolving landscape marked by complex compliance obligations, intensifying regulatory activities, and transformative technological adoption. Early preparation, cross-functional collaboration, and leveraging technology—especially AI—will be critical to navigating the challenges ahead effectively.
Watch this Tax Briefing on demand here.
Looking forward, PwC’s February 2026 Tax Briefing will provide an in-depth focus on Pillar Two readiness, reflecting the vital importance of this emerging area for multinational enterprises—register here.
