International tax & business 2018

The curious reform of foreign source income

Source: The Tax Specialist Journal Article

Published Date: 1 Aug 2018


Proposals currently before parliament which change the tax treatment of foreign source income seem to have been largely overlooked. They deserve greater attention because they produce curious and potentially illogical outcomes for many classes of Australian taxpayers. They are the unpublicised consequences of choices made in the design of Australia's anti-hybrid rules, rules which were intended to curb the aggressive tax avoidance practices of multinational enterprises. Instead, they extend to many types of resident taxpayers earning some classes of foreign source income. This article demonstrates how entirely innocuous situations can be affected and how the impacts can be quite unexpected.

Sorry, this is subscriber only content.

To gain access to this material and much more - Subscribe Now.

(Note: Members can access Taxation in Australia journal articles without a Tax Knowledge Exchange subscription - please log in to access).

Already a Subscriber? Login now

Already a Subscriber? Login now


The material is copyright. Apart any fair dealing for the purpose of private study, research criticism or review, as permitted under the copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.

Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

The Tax Institute
(ABN 45 008 392 372 (PRV14016))


The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009. 

Copyright Statement

All materials provided on this site are protected by copyright and are owned by or licensed to TTI.

Except as expressly permitted by TTI or the copyright owner, any person or company who uses this site must not use, reproduce, redistribute, retransmit, publish or otherwise transfer, or commercially exploit, the materials or any information, software or other content, in whole or in part, which is available through this site.


International tax & business 2018

Share this page