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Published on 13 Aug 2009
| Took place at The Novotel Hotel, Brisbane
Expatriates, both inbound and outbound and their employers and advisers, face unique
challenges and issues in relation to the operation of the Australian Taxation System. In addition, the recent budget changes have added to the complexity that needs to be addressed and
managed. In particular, the changes to section 23AG are now law and apply from 1 July 2009
meaning there is a fundamental change to the tax landscape for Australian’s working overseas and
the planning for structuring those assignments needs to happen now.
In addition to dealing with the changes to section 23AG, this event focused on
some of the more common issues encountered by advisers when dealing with Australians who
are living or working overseas, or for foreign nationals who are living or working in Australia.
These include dealing with transfers of offshore superannuation and pension balances,
understanding and applying double tax agreements and dealing with Australians who have
participated in offshore employee share plans.
This event was aimed at accountants, lawyers and financial planners who advise
individuals that are working or living overseas or have come to Australia to work, live or retire.
This event was also aimed at advisors and employers that send staff offshore or that source
staff for work in Australia from offshore.
Get a 20% discount when you buy all the items from this event.
The government in their May budget announced the removal of this much utilised section of the 1936 Act which allowed for employment income of outbound expatriates to be exempt from Australian tax. This paper explores these amendments and the impact they will have on employees and employers.
The taxation impact on employers include PAYG, pay-roll tax and superannuation obligations and increased FBT costs. Given the changes employers will also face a loss of international competitiveness, increased assignment costs and reduced ability to attract employees on overseas assignments.
Employees will face greater issues such as double tax and the associated cashflow concerns. Accordingly, this paper also explores the alternatives available including the use of foreign income tax offsets and the use of double tax agreements.
Double tax agreements are an important mechanism for assigning taxing rights between two taxing jurisdictions or eliminating issues relating to the double taxing of income. However, due to a lack of understanding of their operation, many advisors may be incorrectly or under utilising these important agreements. This paper explores the use of double tax agreements including "how to" actually read them and "when to" use the agreements for clients where more than one jurisdiction is involved in the taxation of their income. In particular, the more relevant provisions such as the tie breaker tests and the 183 day exemption for employment income as well as those dealing with the limitation of or exemption from tax on certain types of income is covered.
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