Australia may have the right to collect more tax from multinationals such as Uber and Airbnb that send profits through low-tax nations in Europe following this week's historic European Commission decision on Apple.
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But experts warn any tax revenue that may be up for grabs could take years to flow through.
The decision means that the EU could now go after a host of other US multinationals and ignite tax revenue wars.
Just to recap: The EU on Tuesday ruled that Apple should pay back up to €13 billion ($19 billion) in back taxes, plus interest, to Ireland.
EU Commissioner Margrethe Vestager ruled that Ireland was wrong to, in years gone by, give Apple special tax deals as these did not "correspond to economic reality" .
Apple had legally created some clever tax structures, with Ireland at the time offering its full blessing, which amounted to billions of dollars of income flowing tax-free through Ireland's system. The EU ruled that was "illegal state aid".
The White House and the US Treasury Department quickly reacted, saying the ruling was detrimental to US-EU economic relations. And Apple's chief executive Tim Cook called it "total political crap" and vowed the company will appeal.
Multinationals operating in Australia, which channel earnings through nations including Ireland, the Netherlands and Belgium, may now also be impacted. As could be local companies such as James Hardie, that have moved their domiciles to tax-friendly countries such as Ireland.
At last year's Senate inquiry into corporate tax avoidance, Uber admitted that about 25 per cent of each transaction in Australia was routed to its head company in the Netherlands, while Airbnb said 3 per cent of each transaction went via Ireland.
KPMG's Grant Wardell-Johnson says Australia may theoretically decide it can take a similar aggressive approach to multinationals that route profits through Europe. "It is possible that some Australian companies will be affected, but this will take many years to determine," he says.
As highlighted in the Apple case, US authorities don't like it when other nations get too aggressive with US-headquartered multinationals.
More broadly, Wardell-Johnson says, the decision could see more governments acting unilaterally to recoup taxes. For multinationals, that means rethinking aggressive tax strategies. "In the modern era, taxpayers cannot limit their scope of view to black letter law, but instead must look at the broader geopolitics," he says.
ATO getting tougher on multinationals
The EU ruling offers local authorities a strong example of what can be done when companies seek to exploit loopholes. The Australian Taxation Office - once viewed by Australia's corporates as being generous with its tax rulings - also has tougher domestic laws in its armoury through the Multinational Anti-Avoidance Law.
The ATO has long been doing deals with multinationals known as Advanced Pricing Agreements (APAs) that allow companies to lock in future taxes.
Apple has been a beneficiary of those agreements, telling the Senate inquiry in a submission last year that it had got the ATO's blessing for about a decade. But the ATO is now not so quick anymore to agree to such deals.
As of June 30 2016, the ATO has 131 active APAs with multinationals (this compares to 148 active in 2014-15 and 175 active in 2013-14).
It also currently has "107 requests in progress of which 38 are in the early engagement stage". That means if multinationals don't play ball, the ATO may stop rolling some of them over.
"In relation to any organisation, as the relative balance of functions conducted in Australia changes over time, the appropriate profits to be taxed in Australia will also change," an ATO spokesman told Fairfax Media.
"As such, all APAs are regularly reviewed to ensure that they remain relevant and appropriate to the business actually being carried on in Australia, and not simply, 'rolled forward'."
It also noted that while Australia's tax system is not immediately comparable with European Union nations, there is a point at which a line gets crossed. To "transfer misprice to artificially boost profits in lower-taxed countries" is, the ATO says, "unacceptable".
Importantly, the tax agency spokesman added: "This is even more critical where countries provide 'tax holidays' to particular companies or industries", in reference to the US offering multinationals temporary, very low tax rates on those profits to try and get them to bring back funds into the US.
The Tax Justice Network's director of tax John Christensen says the EU's ruling is remarkable not just because of the sheer size of the repayment, but because in her decision EU Commissioner Vestager was explicit in saying that Ireland is not the only loser from these tax avoidance practices.
"Because Apple's sales elsewhere in the world, with the exception of North and South America, have been structured through the legal entities in question, [the] decision has implications far beyond Europe," Mr Christensen says.
Uber - which has a valuation of over US$60 billion - paid just over $403,000 tax in Australia over a three-year period, it was revealed earlier this year.
