PwC’s November 2025 Tax Briefing, hosted by Patricia Muscat, covered Payday Super reforms, Payment Times Reporting updates, and capital management developments—including tax rulings and recent court decisions—with insights from our experts Danielle Anderson, Sean Lee, Zac Yang, Paul Abbey, and Deeti Bhalala.
The briefing included an update on Payday Super reforms, which become effective 1 July 2026. This new legislation will require employers to remit superannuation contributions concurrently with employee salary payments (or within seven business days), a significant shift from the current quarterly system. The briefing detailed the mechanics of this change, including the seven-day payment window, specific exceptions for scenarios like new employees or fund changes, and the three-day allocation window for super funds. Furthermore, it highlighted the new reporting obligations for employers who will need to specify qualifying earnings and super liabilities in each pay event.
The briefing also addressed the Payment Times Reporting regime, which mandates that certain large businesses publicly disclose their payment terms and practices for small business suppliers every six months. A key takeaway was the potential for the slowest 20% of payers to be publicly identified, creating a strong incentive for businesses to improve their payment timelines. Recommendations for clients included proactively checking payment time calculations, assessing their risk of being classified as a slow payer, and engaging with the regulator if they were in the slowest 20% for the June 2025 period and estimate that they will continue to be slow for the December 2025 period.
The final segment addressed a range of complex capital management developments including an analysis of the Australian Taxation Office’s (ATO) compliance approach to equity-funded distributions, outlined in PCG 2025/3, which uses a risk-based framework to assess the frankability of such distributions. The session also examined the intricacies of demerger relief, with a focus on the ‘nothing else’ test and the implications of the recent AusNet case.
Other notable topics included the ATO’s scrutiny of back-to-back rollovers and the resurgent interest in off-market share buybacks by listed companies, along with their associated tax implications for both shareholders and the companies themselves.
You can watch the virtual event on demand now.
