International tax & business 2015

Issues facing parents and subsidiaries in the current international tax climate

Source: The Tax Specialist Journal Article

Published Date: 1 Jun 2015


Multinationals with an Australian connection, whether Australian-based multinationals or foreign multinationals with a presence in Australia, face a range of taxation challenges. This article considers a number of such challenges. The article begins with an overview of the current tax climate for multinationals. The author then examines cross-border financing considerations for parents and subsidiaries, looking at hybrid financing, issues in relation to s 25-90 of the Income Tax Assessment Act 1997, as well as certain foreign exchange issues.

The article then considers some transfer pricing considerations in light of the Chevron case (the decision in which is currently reserved), the possible impact of the reconstruction provision in s 815-130 of the 1997 Act, and expanded documentation requirements. The article concludes with some thoughts on dealing with reputational risk, tax risk management and preservation of legal professional privilege.

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International tax & business 2015

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