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New CGT exposures and exemptions for non-residents paper

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Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

Published on 17 Mar 07 by NATIONAL EVENTS, TAXATION INSTITUTE OF AUSTRALIA

The Government has introduced new provisions to first narrow the focus of CGT for non-residents to Australian real property and permanent establishment assets and secondly introduce a rigorous “land rich” type mechanism that looks through interposed entities. This paper considers:

  • which taxpayers will benefit?
  • how this particular “land-rich” tracing mechanism operates
  • structuring implications
  • tax treaty interactions, i.e. whether Australia has the right to impose this new tax impost
  • assets held through trusts.
This paper was also presented on 3 August 2007 by Ken Spence at the Queensland State Convention in Surfers Paradise.

Author profiles

Richard Shaddick
Richard Shaddick FTIA is a Director of Greenwoods & Freehills in Melbourne. He has extensive experience in international taxation with his primary area of interest being the taxation of controlled foreign companies. Richard is a member of the Public Rulings Panel of the Australian Taxation Office. He is a former State & National Councillor of the Taxation Institute, and a former Australian President of the International Fiscal Association. He represented the Taxation Institute on the Tax Treaties Advisory Panel from 1997-2006. He is an occasional member of the GAAR Panel. - Current at 11 March 2009
Click here to expand/collapse more articles by Richard SHADDICK.
Kenneth Spence CTA-Life
Photo of author, Ken SPENCE Ken is a Special Counsel in the Melbourne office of Greenwoods & Herbert Smith Freehills. He has been closely involved for many years in advising Australian and foreign-owned listed companies on M&A transactions and has been extensively involved with both clients and tax professional bodies in relation to all aspects of the tax consolidation regime. Ken is a past President of The Tax Institute. - Current at 23 August 2016
Click here to expand/collapse more articles by Ken SPENCE.

 

This was presented at Queensland State Convention: Reach for the Stars .

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International tax and the new CGT exposures

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