Tax treaty directions & Div 13/Div 820 Interaction
Published on 06 Aug 2008
| Took place at RACV Club, Melbourne
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.
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