Exhibit 8.2

The Directors   Woodside Finance Limited Mia Yellagonga 11 Mount Street Perth WA 6000 Australia   Woodside Energy Group Ltd Mia Yellagonga 11 Mount Street Perth WA 6000 Australia 29 February 2024

Dear Directors

Private and Confidential

Woodside Finance Limited — Issue of debt securities

Australian tax opinion

We refer to the Registration Statement on Form F-3 (the Registration Statement) of Woodside Finance Limited, which is proposed to be filed with the United States Securities and Exchange Commission on or about the date hereof, relating to the registration of an indeterminate amount of debt securities for future issuance. The Registration Statement contains a tax summary section, headed “Material Tax Consequences—Australian Taxation”, that summarises the Australian tax issues arising for non-resident holders of debt securities issued by the Issuer in accordance with the Registration Statement. You have asked that we provide you with a letter confirming that the Australian tax summary is appropriate for inclusion in the Registration Statement as a general summary of the Australian tax issues.

In preparing this letter, we have reviewed:

• the Registration Statement; and

• the form of Indenture between Woodside Finance Limited (as Issuer), Woodside Energy Group Ltd (as Guarantor) and the Bank of New York Mellon, as trustee (the Trustee) relating to the debt securities and filed as an exhibit to the Registration Statement (the Indenture).

We understand that it is intended that the terms of the debt securities will be set on a basis that ensures that they will be debt interests under Division 974 of the Income Tax Assessment Act 1997 (Cth) and will not be equity interests under that Division. This is based on the following:

• the debt securities will be in legal form debt;

• Woodside Finance Limited’s obligation to repay the principal in full and payments of interest will be non-contingent;

• interest and discount rates on the debt securities will be at the prevailing market rates at the time of the offering; and

• the debt securities will not be classified as equity by reason of any relationship with any other arrangement or as a result of Woodside Finance Limited having the ability to exchange the debt securities for equity interests in any Woodside Group entity.

Based on our review of the Registration Statement and Indenture, we advise that the statements set forth under the heading “Material Tax Consequences—Australian Taxation” are a fair and accurate general summary of the Australian tax treatment of non-resident holders of debt securities who are not also Australian residents and are appropriate for inclusion in the Registration Statement as such a general summary. Our opinion is based on Australian tax law as at the date of this letter. We consent to the inclusion of this opinion as an exhibit to the Registration Statement and to the reference to us under the heading “Material Tax Consequences—Australian Taxation” in the Registration Statement.

Yours sincerely

/s/ Herbert Smith Freehills

Nick Heggart

Partner

Herbert Smith Freehills

+61 8 9211 7593

+61 437 001 229

nick.heggart@hsf.com

Herbert Smith Freehills LLP and its subsidiaries and Herbert Smith Freehills, an Australian Partnership ABN 98 773 882 646, are separate member firms of the international legal practice known as Herbert Smith Freehills.

  Woodside Finance Limited — Issue of debt securities Australian tax opinion page 2