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Corporate Tax Masterclass

Published on 23 Oct 2013 | Took place at Doltone House, Sydney, NSW

Are you across all the key technical issues associated with the critical Corporate Tax developments in the last year? This full day seminar was designed for tax people working in a corporate environment and covers not just the main income tax developments but also some broader issues.

Topics include:

  • tax base erosion and the likely measures to be introduced going forward
  • the practical implications of the changes in the transfer pricing area
  • the new Part IVA
  • an update on tax issues associated with capital management
  • the taxation of foreign exchange gains and losses
  • the most recent developments in the Consolidation Regime
  • an update on Salary Packaging
  • what is happening in the State taxes area
  • current GST issues for corporates.

Get a 20% discount when you buy all the items from this event.

Individual sessions

Tax base erosion - What is likely to be the Australian legislative response going forward?

Author(s):  Richard J VANN

OECD nations are concerned that they are continuing to miss out on their fair share of the global tax take as a result of base erosion and profit-shifting [BEPS] as multinationals seek to improve their bottom line by minimising tax expenses.

This paper covers:

  • the recent initiatives of the OECD, the G8 and the G20 and other countries
  • what is likely to happen in Australia going forward (including Transparency Proposals).
Materials from this session:

Transfer pricing

Author(s):  John ROSS

The recently enacted Cross Border Transfer Pricing legislation imposes a higher obligation on Public Officers of companies to maintain appropriate TP documentation on a contemporaneous basis to defer and defend ATO investigation. Cross border financing, business restructures and profit based assessments where a business has consistently low profits or losses are likely ATO targets.

This practical paper provides guidance on how to develop a framework to adapt to this new TP environment including:

  • ensuring your company’s TP documentation meets the ATO requirements of a reasonably arguable position to avoid automatic penalties should an audit adjustment arise
  • impact on IDS disclosure and your company’s risk profile
  • limitation on period for ATO to amend
  • personal liability of public officers for penalties arising from a false or misleading statements related to TP.
Materials from this session:

Part IVA - Analysis and statutory construction

Author(s):  Eddy MOUSSA,  Harish EKAMBARESHWAR,  Caleb Khoo

This paper covers:

  • the new tax benefit test
  • annihilation versus reconstruction
  • has the relationship between the 3 elements changed
  • the do nothing defence
  • the evidentiary process
  • the EM and its role.
Materials from this session:

An update on capital management issues

Author(s):  Dragan Misic

This paper focuses on some of the major issues facing companies in managing their capital structure including:

  • implications arising from the recently announced changes contained in the 2013-2014 Budget (including the announced repeal of section 25-90)
  • recent changes to the share buy-back rules
  • a review of some of the recent share buy-backs and capital returns by corporates
  • an update on the taxation of share entitlements
  • implications arising from the changes to the Corporations Act 2001 dealing with dividends.
Materials from this session:

Taxation of foreign exchange gains and losses for corporates

Author(s):  Abdol MOSTAFAVI,  Craig Marston

In a volatile exchange rate environment, it is important that taxpayers understand the complex rules governing the taxation of foreign exchange gains and losses. This paper provides an overview of the manner in which the disparate regimes in Division 230 (TOFA), Division 775, the translation rules in Division 960 and “legacy” regimes interact. It also covers some practical case studies aimed at non-financial institution corporate taxpayers who may have:

  • entered into financing arrangements in foreign currency;
  • entered into foreign currency derivatives;
  • made investments in foreign currency denominated assets;
  • made outbound investments in foreign currency.
Materials from this session:

Tax consolidation: Recent changes and interaction with your financial arrangements

Author(s):  Jonathan Rintoul,  Michelle Pigram

This paper explores recent changes and announcements to the tax consolidation rules as they impact financial arrangements and deductible liabilities. In particular it covers:

  • the current status of various changes to the consolidation rules announced as part of the 2013-2014 Federal Budget
  • the 2012 amendments to the TOFA consolidation interaction provisions
  • practical examples to demonstrate the impact of these on transaction values.
Materials from this session:

Update on salary packaging

Author(s):  Donna RUBBO

Salary packaging gives rise to a number of taxation and similar issues, particularly in relation to fringe benefits taxes. With these issues, there arises both traps and opportunities. It is necessary for corporates to keep on top of issues and changes in relation to salary packaging, to ensure that both its own and its staff’s costs are minimized. This paper gives a high level overview of different issues that arise in salary packaging. In particular, it covers:

  • taxation of car benefits
  • major issues affecting salary packaging
  • recent cases and rulings.
Materials from this session:

State taxes update

Author(s):  Cullen Smythe

State taxes remain a constant bugbear for businesses due to their complexity and the seemingly constant changes to legislation and policy. This paper provides an overview of the current most topical State tax issues currently faced by business, including:

  • NSW landholder duty: practical issues for businesses
  • payroll tax update 
  • compliance update.
Materials from this session:

GST update

Author(s):  Martin BOOTH

GST applies to most transactions and it is not something that can be ignored. It is necessary for the impact of this indirect tax to be considered for all transactions and arrangements. This paper gives attendees a high level overview of the changes in the GST arena, with a particular focus on the issues of which corporates should be wary. In particular, it focuses upon:

  • the general anti-avoidance provisions under the GST legislation
  • the continuing issue with going concerns
  • recent cases and rulings that are relevant for corporates.
Materials from this session: