Published on 12 Oct 07
by VICTORIAN DIVISION, THE TAX INSTITUTE
With the Court in McDermott finding that ‘you don’t have to be here to be here’ for PE purposes, this paper examines the PE related issues:
- insights into consequences for internationals PE tax planning including Australia withholding tax implications for Singapore entities and what does the case mean for hiring arrangements and cross border leases
- implications for PE royalty arrangements governed by other treaties
- comparison of the Singapore treaty with other treaties and whether the existence of a treaty really matters
- why the ATO does not want you to have a PE and what action do we expect from the ATO?
Peter VAN DEN BROEK
Current at 25 June 2009
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