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Designed for the specialist tax professional, The Tax Specialist journal is essential reading for corporate tax advisers, accountants, lawyers and academics. Featuring in-depth analysis, opinion and argument on legislative, administrative and judicial issues it is published five times per year and is available by subscription. Also known as the Red Journal.

The Tax Specialist covers the latest issues affecting your role and your business, including:

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  • GST securitisation
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Articles from the current issue:

  • Branch attribution

    shopping_cart Add to cart 01 May 2017

    The attribution of profits to branches or permanent establishments (PEs) is exceptionally complex under Australian law. Branch attribution is also becoming more difficult due to the current base erosion and profit shifting work on branch mismatch structures and Australia’s own introduction of the new multinational anti-avoidance law and diverted profits tax. This article focuses on PE attribution for banks, from an Australian inbound and outbound perspective, and describes how our approach compares to the authorised OECD approach and what other countries are doing in practice. This article also discusses a number of current practical issues and ATO focus areas in branch attribution, and how those issues would be dealt with under the authorised OECD approach. Many of these issues will also be relevant to insurance companies and other financial services entities. The article also considers the future of Australian law in this area.

  • Law, morality and multinationals

    shopping_cart Add to cart 01 May 2017

    The rising political pressure against multinational enterprises (MNEs) that seek to minimise tax liabilities is a global phenomenon. In Australia, even fiscally conservative politicians have been caught up in the populist wave and have introduced a new diverted profits tax (DPT) to bolster the country’s already strong anti-avoidance and transfer pricing rules. This article examines the OECD’s series of actions to prevent MNEs from artificially shifting profits to low or no-tax locations and analyses the “arm’s-length” principle in the Apple Inc case. The author questions why a DPT is necessary when the combination of Pt IVA, the multinational anti-avoidance law and Div 815 ITAA97 leave few gaps in the ATO’s arsenal to deal with tax avoidance behaviour by MNEs. The author also argues that the DPT will only take the broad discretion of the ATO into unchartered waters.

  • The concept of control in Div 6C

    shopping_cart Add to cart 01 May 2017

    The ATO released two controversial documents affecting infrastructure investments early this year. The first document was TA 2017/1, which highlights the ATO’s concern with stapled structures that attempt to re-characterise trading income into passive income to attract concessional tax treatment. The second document was the draft Privatisation and infrastructure – Australian federal tax framework, which updates and expands on documents previously released by the ATO. Both documents have caused a degree of disquiet to investors and advisers who are grappling with what the ATO’s stated positions mean to their investments. The focus of this article is on the concept of “control” for the purposes of s 102N(1)(b) in Div 6C. The authors hope that an appreciation of the issues currently arising might inform the process of developing a framework that will ensure that appropriate levels of taxation are paid while having a minimal effect on business confidence and efficiency.

  • Automatic exchange of information and the common reporting standard

    shopping_cart Add to cart 01 May 2017

    The common reporting standard (CRS) is a framework that provides for the annual exchange of financial accounts information between governments. With a few months to go before the CRS commences, this article examines the need for financial institutions that are already under the Foreign Account Tax Compliance Act (US) (FATCA) to recognise the differences between the CRS and FATCA regimes. Although the CRS is based on FATCA in many ways, the scope of the CRS is much wider. While FATCA only requires the identification of accounts associated with US persons, the CRS requires the identification of all tax residents other than Australia. Many low-risk financial institutions, such as local banks and financial institutions that do not come under the purview of FATCA, will need to review and meet any obligations arising from the CRS. This article also considers how the ATO is working with the industry to provide clarity in the implementation of CRS in Australia.

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