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Current Corporate Tax Issues

Published on 09 Feb 2010 | Took place at Swissotel Sydney, Sydney, NSW

This event brought together leading corporate tax experts to review the most recent developments providing you with an identification of the current tax issues that you need to be aware of.

    Topics included:
  • update on the consolidation regime
  • update on issues relating to capital management
  • employee share arrangements - Where are we now?
  • TOFA - Will it apply to you? Can it apply to you? When will it apply to you?
  • the international tax interface
  • thin capitalisation, transfer pricing and debt deductions.
    This half day event was intended for tax professionals working in a corporate environment (both listed and unlisted) and advisors (to corporate entities) with a predominant income tax background.

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

Individual sessions

Update on the consolidation regime

Author(s):  Jenny CLARKE This paper covers:

  • the use of managed investment trusts (‘MITs')
  • the interaction of Division 855 and the MIT withholding tax regime
  • the particular issues for sovereign wealth funds and foreign pension funds
  • withholding taxes, particularly interest withholding tax issues for leveraged structures
  • the interaction of the Australian tax regime with investor home tax rules.
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Update on issues relating to capital management

Author(s):  Mark GOLDSMITH This paper covers:

  • the proposed changes to the off-market share buy-back rules following the Board of Tax review
  • the latest rulings from the Commissioner, particularly regarding the application of Section 177EA
  • developments in the interpretation of certain elements of the debt test
  • other recent developments regarding corporate capital management.
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TOFA - Will it apply to you? Can it apply to you? When will it apply to you?

Author(s):  Simon JENNER This paper covers TOFA rules and who they apply to.

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The international tax interface

Author(s):  Chris MORRIS This presenation covers:

  • the CFC/FIF recommendations made by the Board of Tax and response
  • developments on thin capitalisation including transfer pricing interaction.
The corresponding paper was authored by Jane Michie and was delivered at an earlier event International Tax Masterclass on 24 September 2009.
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Thin capitalisation and transfer pricing

Author(s):  Richard SHADDICK In November 2007, the ATO released Draft Tax Determination TD 2007/D20. The draft stated: "..the existence of a safe harbour debt amount for the purposes of Division 820 [Thin Cap] does not prevent the Commissioner from determining an appropriate arm's length cost for all of the debt funding ..". This was followed by the release of a Discussion Paper on "Intra-group finance guarantees and loans" in June 2008, and a number of selected references in 2009 speeches by the Commissioner and other ATO officers.

This paper provides an up-to-date report on subsequent progress, including:

  • a summary of the latest ATO position
  • Division 13 and its interface with other arm's length rules
  • the arm's length principle
  • the tax policy perspective.
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Employee share & option arrangements - Where are we now?

Author(s):  David J WILLIAMS A new regime (Division 83A) has been introduced to tax the acquisition of shares and options under employee share arrangements.
This paper covers:

  • the default position - taxed at time of acquisition
  • $1,000 reduction available under broad based schemes
  • deferral of taxing point where there is a "real risk of loss"
  • revised timing of deductions for employers
  • new reporting obligations directly impacting on employers
  • likely audit activity around employee share plans (directly impacting on employees)
  • what is happening with valuation rules?
Note: This paper was also delivered at the event Taxation of Employee Share Ownership
Schemes - The New Rules held in Adelaide on 16 March 2010.
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