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An Introduction to Australia's International Taxation System

Published on 22 Jul 2009 | Took place at Swissotel, Sydney , NSW

Note: This event is a repeat of the same event held on 13 August 2008 in Sydney. All papers have been updated, some significantly.

This intermediate-level event was aimed at practitioners wanting a good understanding of Australia’s international tax system. It was intended for practitioners with a predominant income tax background but not for those who are experienced in how Australia’s international tax regime operates. Topics covered included:

  • how Australian residents are taxed; who is considered a resident?
  • how Australian sourced income is taxed; how is source determined?
  • what are the exceptions and extensions to the foregoing rules?
  • what anti-profit shifting measures operate?
  • what is the impact of Australia’s Double Tax Agreements?
  • how do international withholding taxes work?
  • how are Australian expatriates taxed?
  • how are foreign expatriates working in Australia taxed?

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

Individual sessions

Who is a resident of Australia?

Author(s):  Sanjay WAVDE

This paper covers:

  • who is a non-resident?
  • what are the relevant tests for companies, individuals, trusts & partnerships?
  • is there anyone not covered by the above?
Materials from this session:

How is source determined?

Author(s):  John BALAZS

This paper covers:

  • basic principles regarding the source of income
  • statutory source rules
  • the role of double tax agreements
  • issues with respect to the "source" of statutory income.
Materials from this session:

Extensions, inclusions and attribution

Author(s):  James EATON

This paper covers:

  • controlled foreign companies
  • foreign investment funds
  • transferor trusts
  • participation exemption for non-portfolio dividends and capital gains.
Materials from this session:

Anti profit shifting measures

Author(s):  Garvin ADAIR,  Zubair BANGASH

This paper covers:

  • thin capitalisation and transfer pricing issues for inbound investors and Australian companies investing overseas
  • worked examples of thin capitalisation calculations
  • practical approach to transfer pricing documentation
  • intra-group finance guarantees and loans ATO discussion paper.
Materials from this session:

Australia’s double tax agreements

Author(s):  Robert DEUTSCH

This paper covers topics such as:

  • what is a DTA?
  • the broad principles applied under the Allocation Articles
  • what are the taxes covered by the DTA?
  • is the taxpayer covered by the DTA?
  • business profits
  • passive income
  • annuities and pensions
  • what methods are there in place to avoid double taxation?
  • what procedures are in place to assist in the effective administration of cross-border
    taxation?
Materials from this session:

International withholding taxes

Author(s):  Peter B STINSON

This paper covers:

  • DWT
  • IWT
  • RWT
  • non-resident contractors
  • other withholding obligations
  • obligations on the payer
  • consequences of failure to withhold.
Materials from this session:

Current issues in expatriate taxation

Author(s):  Stephen COAKLEY

This presentation covers:

  • tax residency
  • types of residents
  • interpretation of double tax agreements
  • employer obligations
  • concessions.
Materials from this session: