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2020 International Tax Series

14 October 2020 - 11 November 2020 6.5 CPD hours Online

A case study approach to the international tax management of your clients across all phases of their business

This series is purpose built for practitioners requiring a working knowledge of the many issues and implications affecting their clients when seeking to expand their operations beyond Australia.

The series will begin with a Keynote presentation by Grant Wardell-Johnson, CTA. Grant will cover the topic of tax reform in Australia, with a particular focus on our international tax rules.

Taking a practical approach, this six-part series will explore and delve into the key topics for practitioners to be aware of including:

Selling products overseas from Australia, without any local presence in overseas markets

Organic and inorganic expansion into new markets

Succession planning

Exiting the business through a sale

Based on a dynamic case study, this series will demonstrate scenarios practitioners may find themselves in when assisting their clients, and will offer tips, tricks and strategies for navigating the complexities of Australia’s international tax laws.

Choose a format that suits you:

Attend the live webinars to interact with our expert presenters; or

Replay the webinars (post-event) at a time that suits you

Prices

Member Non member
Full Series Member $385.00 $525.00 Register
Individual Session Member $75.00 $95.00 Register

Program

International Tax Series - Keynote & Part 1: AusCo selling overseas 14/10/20 12:30 PM - 2:00 PM 1.50 CPD hours

  • Keynote Address

    Grant will cover the topic of tax reform in Australia, with a particular focus on our international tax rules.

    Part 1: AusCo selling overseas but no local presence in overseas jurisdiction

    Building off its success in the Australian market, Masks has started to see demand for its products in overseas jurisdictions. Masks is now selling its products to customers in several countries in the Asia-Pacific region via a series of distributors operating as agents for Masks in the overseas jurisdictions. One of Jane and Judy’s business contacts operates a bonded warehouse in Singapore and has agreed to let Masks use this facility for the purposes of warehousing products until sales are made.

    Some of the issues to be addressed in this session include:

    Commercial due diligence on foreign market (e.g. local registrations; local bank accounts)

    Understand agency arrangement and remuneration of agent (Treaty overlay)

    Source under Australian domestic tax law

    Treaty permanent establishment issues around warehousing/storage

    Transfer pricing – location of functions, assets and risks

    Indirect tax issues and customs duties (local jurisdiction)

  • Speakers
    Grant Wardell-Johnson 's profile photo

    Grant Wardell-Johnson CTA
    KPMG

    Carynne Howitt 's profile photo

    Carynne Howitt CTA
    Lion Pty Ltd

International Tax Series - Part 2: Expansion into new markets 16/10/20 12:30 PM - 1:30 PM 1.00 CPD hour

  • Part 2: Expansion into new markets

    In order to facilitate and increase sales in various foreign markets (Europe, Asia and North America) it is decided to have a local presence in the form of an office or use of local agents in those markets. In particular, Masks will establish a presence in the Netherlands, Hong Kong and the US.

    Some of the issues to be addressed in this session include:

    Issues surrounding the nature and extent of presence – for example, representative office, sales and marketing office etc. and whether a permanent establishment is created

    Application of the foreign branch profits exemption – section 23AH

    Thin capitalisation and other funding issues, including interest deductibility in Australia for funds used in the branch

    Foreign tax considerations

    Impact of third party agencies under both domestic tax law and relevant tax treaty

    Indirect issues, VAT/GST, customs duties etc.

  • Speakers
    Brett Curtis 's profile photo

    Brett Curtis ATI
    Grant Thornton

    Andrew Barrah 's profile photo

    Andrew Barrah FTI
    Grant Thornton

  • Part 3: US business expansion, localised development

    As the Masks business continues to successfully expand into the US market, Jane and Judy make the decision to expand their presence in the US from the ‘beach head’ branch to a more permanent presence involving the establishment and operation of a local US entity (USCo).

    USCo will act as the US business operator, including acting as an agent or as a distributor for the Masks business in the US, employing local personnel to fulfil management, business development and operational roles as required.

    Depending on demand and supply, USCo will also ideally establish local manufacturing facilities in the US and develop iterations of the core IP of the business.

    Some of the issues to be addressed in this session include:

    What type of entity to establish

    Treatment of the US entity for Australian tax purposes

    Differences in tax outcomes of agency vs buy/sell

    Secondment of employees and PE risks for Australian legal employers

    Funding, including thin capitalisation,

    Issues and implications of tax residency, both under domestic tax law and treaty

    Transfer pricing US tax issues, including state and local as well as federal, concessions and exemptions, indirect tax issues etc

  • Speakers