Streaming Video Package

ondemand_video Dealing with state revenue authorities regarding stamp duty and land tax video

Presented at: 2021 Local Tax Club Series – Dealing with state revenue authorities regarding stamp duty and land tax (Melbourne)

This video covers:

• Revenue powers of investigation and recent areas of interest
• Reassessment periods
• Obligations to inform the revenue of changes to liability and eligibility for exemptions
• Penalties and interest
• Responding to requests and dealing with authorities
• Applying for private rulings
• Applying for refunds.

ondemand_video Estate planning where there is a foreign element video

Presented at: 2021 Death... & Taxes Conference

This video covers:

• The nature and effect of nationality, domicile and residence
• Jurisdictional issues
• Domestic tax issues
• Certain state taxes, particularly NSW
• FIRB considerations.

ondemand_video Rising dead and buried issues: 100A and 99B video

Presented at: 2021 Death... & Taxes Conference

This video covers:

• When the beneficiaries of non resident estates and testamentary trusts may be taxable on amounts they have not received
• When the resident trustee of a testamentary trust may be taxable on amounts distributed to beneficiaries.

ondemand_video Global CTA – The Digitalisation of Tax video

The digitalisation of tax extends well beyond the investment in technologies by our administrators to gather information (lodgments), improve collections, and gain insights into the taxpaying population. Digitalisation is making global business increasingly more efficient and effective, facilitating cross border transactions with little physical presence. Tax functions, therefore, need to adapt and evolve to meet the needs of administrators and business in an ever changing, multijurisdictional environment. This panel session will cover:

• Global trends in digitalisation
• The impact of digitalisation on tax compliance and the tax base
• Challenges in addressing digitalisation in multijurisdictional tax functions
• How the role of the in-house tax function and that of the professional advisor will evolve in this environment.

ondemand_video A practical approach to financial transactions video

Presented at: 2021 National Transfer Pricing Conference

This video will compare and contrast worked examples of small (less than $10m) and large (greater than $1b) related party loans (including derivatives and outbound interest-free loans) in the current Australian transfer pricing environment.

ondemand_video A new phase in transfer pricing dispute resolution in Australia video

Presented at: 2021 National Transfer Pricing Conference

This video covers:

• The role that your evidence can play in a domestic court strategy relative to a MAP strategy in light of Glencore
• The impact of a multinational group’s domestic dispute resolution strategy (i.e., to settle or to litigate) on potentially achieving a resolution via MAP/arbitration
• For both the multinational taxpayer and the ATO, the tension between preserving rights under domestic tax laws and achieving resolution via MAP / arbitration
• The impact of mandatory binding arbitration on the prospects of achieving resolution via MAP; and
• The OECD’s desire to change the dialogue from ‘dispute resolution’ to ‘dispute prevention’ and what this might mean for multinational groups’ dispute resolution strategies in the future.

ondemand_video Transfer Pricing and the Application of Part IVA video

Presented at: 2021 National Transfer Pricing Conference

This video covers questions that might arise from the intersection of transfer pricing and Part IVA.

ondemand_video Provision of services or rights to use intangibles video

Presented at: 2021 National Transfer Pricing Conference

This video covers the distinction between the provision of services and the granting of rights to use intangibles in interactions between members of MNE groups.

ondemand_video OECD’s Pillar 2 global minimum tax proposal: Taking the pressure off transfer pricing video

Presented at: 2021 National Transfer Pricing Conference

This video covers:

• The current state of play on the OECD’s Pillar 2 program An overview of the Pillar 2 domestic law change proposals (the income inclusion rule and the undertaxed payments rule, together known as the GloBE rules) including identifying which entities are in-scope, the effective tax rate (ETR) calculation and identifying who pays the top-up tax
• An overview of the Pillar 2 treaty based changes (the switch-over rule and subject to tax rule)
• An analysis of implementation issues and next steps
• Consideration of the major impacts of the changes, especially on transfer pricing.

ondemand_video The ATO’s intangibles strategy and draft PCG on intangibles video

Presented at: 2021 National Transfer Pricing Conference

This video covers:

• The ATO’s intangibles strategy
• Draft PCG on intangibles
• Practical application.