Ref: AMK:lg
21 August 2026
The Treasury Langton Crescent Parkes ACT 2600 AUSTRALIA By Email: TaxChanges@treasury.gov.au Dear Sir / Madam CAPITAL GAINS TAX AND NEGATIVE GEARING – TRANCHE 2 LEGISLATION 1.
Thank you for the opportunity to provide comments on Capital Gains Tax and Negative Gearing – Tranche 2 Legislation (Draft Legislation).
2.
Pitcher Partners specialises in advising taxpayers in what is commonly referred to as the middle market. Accordingly, we service many privately owned business and investment groups that are impacted by compliance burdens in the tax system, both legislative and administrative. Our submission focuses on compliance burdens affecting privately controlled groups.
3.
We highlight that for the purposes of Division 30 of the Tax Agent Services Act 2009 and, in particular, the amendments to the Code of Conduct by the Tax Agent Services (Code of Professional Conduct) Determination 2024 (“Determination”), all of the comments made in this submission are directly relevant to us a as a firm and our clients. While this may result in a conflict of interest for the purposes of section 20 of the Determination, we highlight that we have tried to ensure that our comments and suggestions in this submission are balanced and consistent with the policy, principles and intention of the rules as we understand them.
4.
We continue to hold concerns regarding the complexity associated with the deemed sale and reacquisition framework that underpins the capital gains tax reforms. In particular, the framework gives rise to a broad range of interaction issues with existing provisions of the tax law, many of which remain unresolved. Consistent with our
696263_2