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Tax treaty directions & Div 13/Div 820 Interaction

Published on 06 Aug 2008 | Took place at RACV Club, Melbourne, VIC

Part of the Corporate Tax Club series, this event explored the themes outlined below.

Australia is set to continue renewing and expanding its tax treaty network, with recommendations to focus on our Asian trading partners. What can we learn from recent treaties and protocols, and from Australia's broader treaty network, as to likely directions? How will these directions interact with our domestic law?

Some of our most fundamental interactions have been questioned recently. The June 2008 ATO discussion paper and TD 2007/D20 ask whether the arm's length principle in Div 13 qualifies the more specific Div 820 thin capitalisation rules. Could that be correct? Could the arms' length rules in the treaties do the same thing? The suggestion is that not only your pricing must be at arm's length, but also the capital structure of your business. That would have wide reaching implications for both inbound and outbound investment.

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

Individual sessions

Tax treaty directions

Author(s):  Richard J VANN

This presentation covers:

  • background
  • current issues
  • how to implement international solutions
  • Australia's future tax treaty policy.


Materials from this session:

Treaty directions and Division 13/ Division 820

Author(s):  Michael JENKINS

This presentation covers transfer pricing, financing and related issues, including the following aspects:

  • background
  • ATO approach
  • ATO observations
  • ATO reaction.
Materials from this session: