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International Day

Published on 10 May 2013 | Took place at City West Receptions, Perth, WA

Looking for a refresher on international tax issues? This seminar focused on core concepts and provided a useful refresher on key issues as well a focus on recent developments and proposed changes to the international tax landscape.

    Topics covered included:
  • key international tax considerations for investing into and out of Australia
  • residency the new frontier
  • tax treaties – what are they and what do they do?
  • cross border transactions and tax controversy
  • transfer pricing landscape
  • a stocktake of announced but unlegislated measures

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

Individual sessions

Key international tax considerations for investing into and out of Australia

Author(s):  Kenneth WEE,  Zubin SADRI

This presentation provides a general overview of the key international tax considerations for foreign investors contemplating investment into Australia and also Australian corporations expanding their investments overseas. With the Government’s focus on international tax reform, this presentation covers some of the critical Australian taxation areas which need to be addressed in operating in a global market, including:

  • basic structuring considerations
  • financing considerations (incl. thin cap/TP, withholding taxes and hybrid financing)
  • profit flow considerations to provide returns to investors (incl. foreign dividend/branch profits exemptions\
  • withholding taxes and CFI)
  • future exit from the investment (incl. participation exemption, non-resident CGT and source)
  • other (incl. FITOs, CFC rules, treaty overlay).
Materials from this session:

Tax residency and double tax agreement

Author(s):  Tony UNDERHILL,  Katya KROTOVA

For Australian employers looking for opportunities overseas a key consideration in reviewing their project costing is the tax residency of their workforce. Similarly, for an Australian taxpayer looking at opportunities overseas, whether it’s a working trip around Europe or an assignment in Asia, the question of their residency for taxation purposes can have a significant impact. Also, there is an increasing number of foreign workers coming to Australia, both permanently and temporarily, and there are often questions about their residency for taxation purposes.

This paper reviews the legislation and consider current rulings, practices and tax planning in the following areas:

  • categories of residency
  • becoming an Australian resident
  • changing from a temporary to a permanent Australian resident
  • ceasing to be an Australian resident
  • double tax treaties
  • the effect on self-managed superannuation funds, family trusts and other entities.
Materials from this session:

Tax treaties - What are they and what do they do?

Author(s):  Mathew CHAMBERLAIN

This presentation focuses on the practical impact and application of Australia’s Tax Treaty network, as it applies to both Australian businesses operating offshore and foreign businesses operating in Australia.

Topics covered include:

  • the fundamentals of Tax Treaties, including their purpose, effect and interpretation
  • core concepts, eg residence, permanent establishments, business profits, withholding taxes etc
  • their interaction with Australian domestic tax law
  • some practical examples and issue involving the application of Treaties.
Materials from this session:

Cross border transactions and tax controversy

Author(s):  Rob BENTLEY,  Michael BONA

This presentation covers:

  • introduction
  • part IVA framework
  • part IVA amendments
  • can you opine on part IVA?
  • evidence review
  • case study.
Materials from this session:

Responding to Australia's transfer pricing reforms

Author(s):  Janelle Sadri

This paper discusses Australia’s transfer pricing landscape and the ATO’s focus on transfer pricing and profit shifting. Specifically, it offers:

  • an overview of Australian transfer pricing reforms over the past 18 months, and the local / global (OECD) focus on profit shifting and base erosion
  • discussion on both the technical aspects and key practical implications of Australia’s new transfer pricing rules for taxpayers
  • hot topics / focus areas for revenue authorities (e.g. business restructures, financing, intangible property, (marketing) services transactions)
  • an update in terms of the ATO’s transfer pricing compliance enforcement activity – including the International Dealings Schedule, risk reviews and audits.
Materials from this session:

An update on Government (in)activity

Author(s):  Narelle MCBRIDE,  Nick HEGGART,  Tristan Boyd

This paper covers:

  • outstanding forex amendments
  • foreign source income attribution rules
  • new managed investment trust regime
  • sovereign investment into Australia
  • investor manager regime changes
  • foreign bank branches and Division 230
  • GST changes for cross-border transactions.
Materials from this session: