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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:

Kenneth Spence CTA-Life
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 Click here to expand/collapse more articles by Ken SPENCE.
Richard Shaddick FTI
Richard is a Director in the Melbourne office of Greenwoods & Freehills. He has specialise in international taxation for many years, especially (since 1990) in the Australian taxation of controlled foreign companies (CFCs). Apart from advising private sector clients in this area, Richard also serves on the Rulings Panel of the Australian Taxation Office, and has consulted extensively with the Treasury Department on the redesign of the CFC legislation. Current at 01 July 2010 Click here to expand/collapse more articles by Richard SHADDICK.

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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