Published on 13 Feb 09
by NATIONAL DIVISION, THE TAX INSTITUTE
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.
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
The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009.
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