TOFA–The international dimension paper

Member Price: $57.00

Non Member Price: $75.00

Publication date: 13 Feb 09

Source: NATIONAL DIVISION, THE TAX INSTITUTE

Abstract:

This paper examines:

  • the application of TOFA to cross border financial transactions
  • how TOFA affects foreign banks, internal transactions of banks and OBUs
  • interaction with the rules on forex gains/losses, withholding tax and CFC/FIF regimes
  • change of residence by companies and individuals.

Author profile:

Anthony Frost CTA
Tony is the Managing Director of Greenwoods & Freehills. With more than 25 years experience in tax, Tony has a focus on financial services and financial transactions. Tony has advised clients on a wide range of tax matters, including innovative financial products, mergers and acquisitions, cross-border dealings, transfer pricing, tax audits and negotiations with the Australian Taxation Office. Tony has also advised clients on various OBU matters over many years, and is part of the consultation group set up by Treasury to discuss changes to the OBU rules announced in the previous government’s 2013-14 Budget.
Current at 18 October 2013
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This was presented at Financial Services Taxation Conference 2009.

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Individual sessions

Hedging workshop

Author(s):  Julian HUMPHREY

Materials from this session:


TOFA and hedging

Author(s):  Mathew UMINA

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Tax issues in a bear market: Assets side

Author(s):  Allan BLAIKIE

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Tax issues in a bear market: Liabilities side presentation

Author(s):  Patrick BROUGHAN

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Profit attribution to permanent establishments and transfer pricing following the Roche case

Author(s):  Nick HOUSEMAN

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Financial services tax update

Author(s):  Antoinette ELIAS

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Thin capitalisation including the impact of falling asset values

Author(s):  Paul BALKUS,  Daryl CHOO

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Developments in the administration of promoter penalties

Author(s):  Bruce COLLINS

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The capital revenue debate and the managed funds review

Author(s):  Andrew MILLS

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Managing TOFA, implementation and ongoing–Tax Office perspective

Author(s):  Ross BROOKES

Materials from this session:


Managing TOFA, implementation and ongoing–The TOFA countdown has begun

Author(s):  Neil WARD

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Annual compliance arrangements

Author(s):  Stephen GREEN

Materials from this session:


Superannuation update

Author(s):  Shayne CARTER

Materials from this session:


TOFA for the clients of financial institutions

Author(s):  David LINKE

Materials from this session:


TOFA–The international dimension

Author(s):  Tony FROST

Materials from this session:


Walking the wire-The Australian economy in 2009

Author(s):  Michael BLYTHE

Materials from this session:


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