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Written by practitioners for practitioners Taxation in Australia is continually ranked as Australia's leading tax journal.

Published 11 times per year, the 'blue journal', as it is affectionately known, is available exclusively to members.

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This comprehensive publication features articles with a strong, practical approach to the latest tax issues and professional development.

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Articles from the current issue:

  • Implications from the High Court decision in Placer Dome

    shopping_cart Add to cart 01 May 2019

    In December 2018, the High Court handed down the much-anticipated stamp duty decision in Placer Dome. Although the assessment under consideration was issued on the basis that Placer Dome was land-rich under stamp duty provisions that have since been repealed, many of the issues considered by the High Court remain significant under the current provisions in various jurisdictions. This article considers the broader implications of the decision relating to the identification of goodwill and the valuation of land and other assets, particularly in the mining context. These issues may also be relevant in a range of contexts other than stamp duty, including tax consolidation, thin capitalisation and capital gains tax.

  • “Practical” safe harbours and Australia’s transfer pricing rules

    shopping_cart Add to cart 01 May 2019

    In the context of complex intra-group dealings, the ATO is placing increasing reliance on the use of practical compliance guidelines (PCGs) to inform the market as to their view of transfer pricing risk for specific categories of international dealings. These PCGs can therefore assist Australian taxpayers in understanding transfer pricing issues of concern to the ATO and how to focus economic analyses demonstrating compliance with the transfer pricing provisions. Of critical importance, though, is the way PCGs are used by the ATO. Their legal status does not go beyond that of a statement of the ATO’s view of risk, so it is important the transfer pricing “risk indicators”, being the key element of the PCGs, are not linked to arm’s length outcomes.

  • Modified IRS remediation program: Are you wilful?

    shopping_cart Add to cart 01 May 2019

    In late 2018, the Internal Revenue Service (IRS) closed the Offshore Voluntary Disclosure Program and has since released an updated voluntary disclosure program with significant operational and procedural changes that will impact taxpayers seeking to enter the program. Members of wealthy Australian families who relocate to the US, or members of US-based families moving to Australia, are often doing so without being fully aware of the stringent reporting and filing requirements on foreign assets, financial accounts and asset holdings they will be subject to. This invariably results in taxpayers seeking to enter into remediation programs to limit or mitigate penalty exposure on misreporting and non-compliance with the IRS. Deciding which program is best for a taxpayer is imperative and can now result in further penalty exposure where a lack of analysis of the facts and circumstances surrounding the non-compliance is conducted. The question remains: have you been wilful?

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