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An Introduction to Australia's International Tax System

Published on 18 Aug 2011 | Took place at Sydney Harbour Marriott, Sydney, NSW

This event heard from a wide range of international tax experts who provided a comprehensive introduction to the current international tax regime operating in Australia.

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Individual sessions

Who is a resident of Australia?

Author(s):  Clint Harding

This paper covers:

  • basic principles of international taxation - Residence & source
  • significance of residence
  • meaning of "Australia"
  • individuals
  • double tax agreements and dual resident of individuals
  • consequences of ceasing to be Australian resident
  • companies
  • superannuation funds.
Materials from this session:

How is source determined?

Author(s):  Cory HILLIER

This paper covers:

  • why is the determination of the source of income important?
  • when does the determination of source become critical?
  • what is the meaning of "source" of income?
  • what is the meaning of Australia and what is its impact on the determination of “source”?
  • what is the “source” of business income and trading income?
Materials from this session:

Extensions, inclusions & attributions

Author(s):  Matt BUDGE,  Wendy Hartanti

This paper covers:

  • the CFC rules
  • the proposed FAF provisions
  • the transferor trust rules
  • participation exemptions
  • foreign income tax offsets.
Materials from this session:

Anti profit shifting measures

Author(s):  John ROSS

This paper covers:

  • debt/equity rules
  • transfer pricing - Divison 13 ITAA 1936
  • thin capitalisation.
Materials from this session:

Double tax agreements

Author(s):  Bob DEUTSCH

This paper covers:

  • the broad principles applied under the allocation articles
  • what are the start dates and termination arrangements in relation to the DTA?
  • what are the taxes covered by the DTA?
  • business profits
  • passive income
  • annuities and pensions
  • professors and teachers
  • students
  • dependent services (employees).
Materials from this session:

International withholding taxes

Author(s):  Peter B STINSON

This paper covers:

  • liability for withholding tax
  • withholding tax rates
  • foreign resident withholding regime for certain payments
  • managed investment trusts - Withholding regime for fund payments
  • collection of withholding tax.
Materials from this session:

Current issues in expatriate taxation

Author(s):  Stephen COAKLEY

This presentation covers:

  • tax residency
  • types of tax residents
  • residents
  • tax effective salary packaging
  • foreign residents
  • interpretation of double tax agreements.
Materials from this session: