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The New International Tax Regime

Published on 03 Jun 2004 | Took place at Le Meridien at Rialto, Melbourne, VIC

On 1 April 2004 the Federal Government introduced into Parliament the New International Tax Arrangements Bill (Participation Exemption and Other Measures) 2004 which resulted in significant changes to Australia's international tax regime.

The 2004 Bill proposed:
- an exemption for all non portfolio dividends
- an exemption for active foreign branch income and capital gains
- a new CGT concession for capital gains arising from disposal of non portfolio interest in active foreign companies
- a new tainted services income rule for Controlled Foreign Companies.

These seminar materials examine in detail the new provisions and the practical implications of:
- the new foreign source income tax exemptions and consequential impacts
- the new CGT concession
- the NITA Bill 2003 (introduced December 2003) - in particular, the Foreign Investment Fund measures.

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

Individual sessions

The New Foreign Source Income Regime: Dawn of a New Era

Author(s):  Jason CHANG This presentation focusses on the key practical impact of the new foreign source income regime including:
- background
- the foreign source income regime - current vs new
- the non portfolio dividend exemption
- the foreign branch profits rules
- consequential impacts arising
- the proposed new BELC regime
- new tainted services rule
- what's on the horizon.

Materials from this session:

The new CGT rules for shares in active foreign companies

Author(s):  Cameron RIDER This paper covers:
- background and policy
- the general principles to qualify for the concession
- active business assets - what is excluded?
- valuation methods - market value vs book value - which should you choose?
- impact of accounting
- practical issues relating to active business asset percentage
- multi tier corporate structures
- consolidated foreign accounts
- what this means for business.

Materials from this session:

New International Tax Arrangements Bill 2003

Author(s):  Marco FELTRIN This paper covers the following:
- status of bill
- the FIF measures
- balanced portfolio exemption
- impact for managed funds and superannuation funds
- practical issues arising from the FIF measures
- interest withholding tax exemption.

Materials from this session: