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International Masterclass

Published on 14 Sep 2011 | Took place at Sydney Harbour Marriott, Sydney, NSW

While carbon and resource taxes dominate the political headlines, international tax reform remains a high priority for the government.

This event presented by leading international tax experts offered an insight on the recent international tax changes. The event comprised of in-depth discussions of the business impacts of recent developments through case studies and practical insights.

This event was a must for anyone dealing with cross-border transactions or with a serious interest in international tax. This masterclass is intended for tax directors and managers in corporates, advisors and structured finance professionals.

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

Individual sessions

Renovating the CFC and FIF regimes and rethinking outbound structures

Author(s):  Alison RODI,  Peter MADDEN

This paper covers:

  • explanation of proposals
  • aspects of the ed on CFCS requiring further consideration and review
  • rethinking current structures.
Materials from this session:

Renovating the CFC and FIF regimes - Where are we at?

Author(s):  Alison RODI

This presentation covers:

  • Australia's new outbound regime
  • the journey so far
  • next steps/Timing
  • overview of proposed legislation
  • overview of key CFC provisions
  • returns on foreign investment rules
  • foreign trusts.
Materials from this session:

IBM on withholding - What it means

Author(s):  Simon THORP,  Erin Saunders

This paper covers:

  • background: Legislative provisions
  • the IBM case
  • ATO guidance
  • the Icebergs.
Materials from this session:

Recent trends in transfer pricing litigation in Australia

Author(s):  Paul MCNAB,  Peter Callejah,  Colin Little

This paper covers:

  • the SNF decision
  • evidentiary challenges
  • attempts to stem the tide of losses
  • evidence of a global market
  • OECD guidelines
  • Roche Australia v the Commissioner of Taxation
  • relevant facts
  • expert reports
  • appropriate choice of comparables
  • contract between RB and Bayer AG ("Inhibace")
  • choice of OECD methodology.
Materials from this session:

Reportable tax positions

Author(s):  Miquel P. TIMMERS

This presentation covers:

  • question? (and why are we doing this?)
  • benefit? (and can the ATO deliver them?)
  • risk? (and the cost?)
  • solution? (build a better mouse trap?).
Materials from this session:

Part IVA and international transactions

Author(s):  Robert DEUTSCH

This paper covers:

  • Citigroup Pty Ltd v. FCT (2011)
  • Noza Holdings Pty Ltd v. FCT (2011)
  • FCT v. News Australia Holdings Pty Limited (2010)
  • British American Tobacco Australia Services Ltd v The Commissioner of Taxation (2009) 13
  • the key messages from the cases.
Materials from this session:

Foreign hybrids - Where are we now?

Author(s):  Andrew Hirst,  Julian PINSON

This paper covers:

  • background to Division 830
  • definition of “foreign hybrid”
  • application of the “foreign hybrid” definition to specific entities
  • partnership treatment of foreign hybrids
  • disposal and cost base issues.
Materials from this session:

Inbounds tips and traps

Author(s):  David SHORT,  Tasha CHUA

This paper covers:

  • corporate inbound considerations
  • TPG Myer flow on
  • funds management
  • financing considerations
  • global trends and policy update – What to focus on going forward.
Materials from this session: