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27 May 11 International Sub-committee

Janie Michie FTIA (Macquarie Group) chaired a meeting of The Tax Institute’s International sub-committee on Monday 23 May 2011. The meeting was convened following the inaugural meeting of the NTLG International sub-committee last week. As noted in last week’s TaxVine report of that meeting, the new NTLG International sub-committee was formed following the amalgamation of the NTLG Foreign Source Income sub-committee and NTLG Transfer Pricing sub-committee. The NTLG new committee will cover both transfer pricing and international issues, including matters such as CFC/FAF, foreign hybrids, the branch profit exemption, source rules, treaties and withholding taxes.

Our International committee’s work in the last 6 months has included drafting a detailed submission on the CFC/FAF ED, as well as contributing to the drafting of joint submissions on TD 2010/D7 and D8 (the most recent private equity determinations).  The committee will be continuing to engage with the Treasury on the development of the new CFC/FAF rules, particularly regarding concerns about disconnected income issues.

Our International committee is pleased that the ATO is devoting significant resources to the new NTLG International committee, which is scheduled to meet bi-monthly. It was decided that it is important to support this new committee by regularly raising pertinent international and transfer pricing issues, as well as making submissions to the ATO to assist them in resolving technical issues. To ensure we regularly contribute to the NTLG committee, our committee will also meet bi-monthly, in the alternate month to the NTLG.

We welcome the submission of potential NTLG issues from all members. If you have an issue that you would like raised, please contact us at Tax Policy.

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