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Tax issues for foreign institutional investors paper

Published on 10 Oct 08

Australia's ongoing resources boom has attracted a great deal of foreign investment into our equity capital markets, some of which has been sourced from global resources companies, and some from global investment funds (including foreign governments' sovereign wealth funds). The recent downturn in global credit and equity markets makes it quite timely to consider what tax principles might apply to the divestment of such investments. This paper covers:

  • institutional investors - rethinking the capital/revenue distinction in a post-CGT environment
  • the source of income from Australian investments
  • applying the tracing rules to identify taxable Australian property
  • international tax aspects of scrip-for-scrip rollovers and demergers
  • sovereign wealth funds.

Author profile:

Duncan is Head of the National Tax Team at Blake Dawson. He was previously a Partner in the International Tax Group of a global accounting firm. Earlier this year Duncan served as one of the three private sector representatives on the Federal Government’s Tax Design Review Panel.
Current at 11 March 2009 Current at 14 May 2009 Click here to expand/collapse more articles by Duncan R C BAXTER.


This was presented at 2008 Victorian State Convention .

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