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Treaty shopping paper

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Published on 07 Oct 10 by VICTORIAN DIVISION, THE TAX INSTITUTE

This paper covers:

  • prevention of treaty shopping
  • overview of TPG/Myer transaction in the context of treaty shopping
  • addressing treaty shopping in an Australian context.

Author profiles

Jayde Thompson
Jayde is a Senior Manager in the Corporate Tax Services Group of PricewaterhouseCoopers in Melbourne where she specialises in international tax and M&A. Over the past 7 years, Jayde has worked on a large number of domestic and cross border transactions both in Australia and New York. Jayde was recently seconded to the Board of Taxation where she was involved in the review of the Arm's Length Debt Test, Taxation of Financial Arrangements and the post-implementation review of the Debt and Equity tax rules. - Current at 30 August 2017
Click here to expand/collapse more articles by Jayde THOMPSON.
Paul Korganow
Photo of author, Paul KORGANOW Paul is the ATO Assistant Commissioner for the International Tax Structuring/BEPS Practice • Public Groups & International. Paul manages the Melbourne International Structuring and Profit Shifting (ISAPS) team. He is also involved in strategy development and contribution to domestic and multilateral law reform around BEPS. Paul is the ATO Project Lead for BEPS Action 2 and represents the ATO on the Board of Taxation Working Group looking at the domestic implementation of the OECD Anti-Hybrid Rules. Paul was previously a Partner at Deloitte and EY in their International Tax and M&A groups. - Current at 30 August 2017
Click here to expand/collapse more articles by Paul KORGANOW.
Chetan Prabhu
Chetan is a Senior Manager at Ernst & Young. - Current at 30 August 2017

 

This was presented at 49th Victorian State Convention .

Get a 20% discount when you buy all the items from this event.

Individual sessions

Can the Commissioner of Taxation be the great dissenter?

Author(s):  Neil YOUNG

Materials from this session:

TOFA - Much Ado?

Author(s):  Mark POOLE

Materials from this session:

Controlled foreign companies - A modern approach

Author(s):  Richard SHADDICK

Materials from this session:

Transfer pricing - The winds of change

Author(s):  Helen FAZZINO

Materials from this session:

Small business CGT concessions - Opportunities and traps

Author(s):  Robert WARNOCK

Materials from this session:

International tax for private groups in a changing world

Author(s):  Denise HONEY,  Yina Tang

Materials from this session:

Corporate tax governance and risk

Author(s):  Cheryl-Lea FIELD

Materials from this session:

Treaty shopping

Author(s):  Paul KORGANOW,  Chetan PRABHU,  Jayde THOMPSON

Materials from this session:

Division 7A strategies

Author(s):  Andrew O'BRYAN

Materials from this session:

Executing transactions: Recent developments in M&A

Author(s):  Paul ABBEY,  Rebecca Choong

Materials from this session:

Trust deed issues in a post-Bamford world

Author(s):  Graeme HALPERIN

Materials from this session:

Debt which does not generate assessable income

Author(s):  Cameron RIDER

Materials from this session:

Changing the rules in the US multinational tax hikes pay for spending priorities

Author(s):  John Womack

Materials from this session:

Post-Bamford trustee resolutions

Author(s):  Nabil (Bill) F. OROW

Materials from this session:

Dancing with the dragon

Author(s):  Anthony KLEIN,  James STRONG

Materials from this session:

GST developments

Author(s):  Jeremy GEALE

Materials from this session:

The 'new' superannuation environment

Author(s):  Noelle KELLEHER

Materials from this session:

Consolidation: After the smoke clears

Author(s):  Alexis KOKKINOS

Materials from this session:

Further details about this event:

 

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