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International Tax Masterclass
Published on 14 Oct 1999 | Took place at Menzies Hotel , NSW
This seminar looks at the latest developments in the taxation of international transactions, with particular emphasis on: Ralph recommendations; e-commerce; GST; transfer pricing; withholding tax; foreign investment funds.
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Individual sessions
Transfer pricing - current hot spots
Author(s):
Stephen BRECKENRIDGE
This presentation focuses on an Overview of the ATO's RRIP initiative, problems with comparability of data, advance pricing arrangements, penalties, and future directions. It outlines : Recent important ATO Transfer Pricing Rulings; Increased emphasis and development of Schedule 25A questions; Available TPM's; Extent of written documentation; Risk of ATO audit; Document enforcement; Major RRIP experiences; Controversial transfer pricing activity; "Commercial realism"; ABS data; ABS versus ATO statistics; Advance Pricing Arrangements; Penalties; and Ralph Business Tax Reform Recommendations.
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International aspects of GST
Author(s):
Robert DEUTSCH
A detailed description of how the GST will effect our international relationships.
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Foreign investment fund amendments
Author(s):
Peter NORMAN
Amendments to the Foreign Investment Fund ("FIF") provisions in Part XI of the Income Assesment Act 1936 were contained in the Taxation Laws Amendment Bills. The principal change was the inclusion of a new exemption for interests held in certain US entities, provided in a new Division 8 of Part XI.
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Ralph report recommendations
Author(s):
Michael RIGBY
This paper focuses on the recommendations that are relevant for structuring investments by non-residents into Australia, and that impact on Australian corporates with offshore operations. In considering how the recommendations will affect non-residents investing into Australia, the paper discusses the proposals to tax unfranked inter-entity distributions, to tax trusts as separate entities, to extend the scope of the thin capitalisation provisions to all debt and to extend the scope of the capital gains provisions to apply to certain disposals of shares in non-resident companies.
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Withholding tax developments
Author(s):
David TEMBY
In 1997 and 1999 important changes were made to the interest withholding tax (IWT) provisions of the Income Tax Assessment Acct 1936. These changes include amendments to the exemption available under section 128F of the Act. This presentation outlines : Extended definition of "interest"; The pre-July withholding tax liability; What the TLAA2 1997 Amendments do; The Government's response; When a 128F IWT exemption is available; The "public offer" test; Offers by dealers; ATO guidance; The problem with associates; The bearer debenture rules problem; What are the practical advantages of the new regime; What records should be kept; PAYG reforms
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A consolidation regime
Author(s):
C.J GETZ
Topics discussed include: moving towards consolidated group taxation: a process of consultation; Ralph recommendation 15.1; consolidation - what will help; general principles for consolidation.
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