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Re-targeting capital gains tax for non-residents:Proposed Division 855 - 'Winners and Losers'


The taxation of inbound investments into Australia stands to be dramatically altered by the proposed provisions of Division 855 that have recently been introduced into Parliament. This re-targeting of capital gains tax for non-residents will be beneficial for some non-residents but for others with investments in Australian “land-rich” entities, this will certainly not be the case.

This paper was also presented at the 'International Tax Masterclass' held in Sydney on 27 September 2006. 

Author profiles

Richard Shaddick
Richard Shaddick FTIA is a Director of Greenwoods & Freehills in Melbourne. He has extensive experience in international taxation with his primary area of interest being the taxation of controlled foreign companies. Richard is a member of the Public Rulings Panel of the Australian Taxation Office. He is a former State & National Councillor of the Taxation Institute, and a former Australian President of the International Fiscal Association. He represented the Taxation Institute on the Tax Treaties Advisory Panel from 1997-2006. He is an occasional member of the GAAR Panel. - Current at 11 March 2009
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Kenneth Spence CTA-Life
Photo of author, Ken SPENCE Ken is a Special Counsel in the Melbourne office of Greenwoods & Herbert Smith Freehills. He has been closely involved for many years in advising Australian and foreign-owned listed companies on M&A transactions and has been extensively involved with both clients and tax professional bodies in relation to all aspects of the tax consolidation regime. Ken is a past President of The Tax Institute. - Current at 23 August 2016
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This was presented at International Tax Masterclass 2006 .

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Individual sessions

Structuring real estate investments into continental Europe

Author(s):  Matthijs VOGEL

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