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International Masterclass 2012

Published on 17 Oct 2012 | Took place at Four Seasons, NSW

    This seminar, presented by leading international tax experts, offered an insight on the recent international tax changes. The day 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 was intended for Tax Directors and Managers in corporates, advisors and structured finance professionals.
    Topics covered included:
  • A stocktake of announced but unlegislated measures
  • Practical Implications and considerations arising from changes to the transfer pricing regime
  • The implications and consequences of Related Party Debt
  • What the ATO is doing in the area of exchange of and access to information in the LBI Market – what the taxpayer can expect
  • Part IVA & International Transactions
  • LAFHA Changes
  • The Residence of Companies and Trusts revisited
  • The cross border/international aspects of the new R&D regime.

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

Individual sessions

An update on government inactivity

Author(s):  Narelle MCBRIDE

This paper provides an update on government ‘unfinished business’ with a focus on international issues. Most importantly, it provides some guidance on making decisions or advising clients in our current environment of announced government policy that has stalled and unknown retrospective legislative amendments.

This paper will:

  • identify key announcements; and
  • consider strategies for dealing with the uncertainties that these announcements cause.


Materials from this session:

Practical implications arising from changes to the Australian transfer pricing legislation

Author(s):  Paul BALKUS

The current and proposed changes to the transfer pricing legislation have potentially significant implications for many taxpayers that will need to be addressed. This presentation provides an overview of the background and drivers for the legislative changes as well as the practical implications and actions that may be required by taxpayers.

The presentation covers:

  • background and drivers for change in the Australian transfer pricing legislation
  • implications for historical and future  transfer pricing positions
  • taxpayer profiles and  "trigger transactions" impacted by the legislative changes
  • treaty partner considerations
  • transfer pricing documentation and disclosure requirements.
Materials from this session:

Exchange of and access to information

Author(s):  Michael O'NEILL,  David ALLEN

This presentation covers the ATO’s broad approach to data collection and its powers including:

  • Access to information provided to third parties
  • Information coming from other agencies
  • Information coming into the possession of the ATO from third parties
  • Tax information sharing arrangements under DTAs and TIEAs
  • Multi-lateral Convention and its ratification.
Materials from this session:

Reforms to living-away-from-home allowances

Author(s):  Elizma BOLT

A discussion of the changes to the tax treatment of “benefits” provided to employees living away from the usual places of residence on a temporary basis and what it means for both employees and employers.

This paper covers: 

  • background of the taxation of living away from home fringe benefits
  • rationale for changes 
  • summary of changes 
  • what does this mean for employees and employers?
Materials from this session:

The cross border/international aspects of the new R&D regime

Author(s):  Ian Ross-Gowan

The new R & D regime commenced in 2011 and it contains a number of significant changes generating the loss of existing opportunities and the creation of new opportunities.

This paper covers:

  • who and what qualifies now that did not qualify before
  • what does not qualify now that did qualify before
  • the opportunity to secure claims via Overseas and Advance Findings
  • new opportunities to encourage international R&D to be done in Australia 
  • relaxing of rules allowing international ownership of R&D project IP
  • other changes to the incentives
  • what your company needs to be doing differently.
Materials from this session:

The residence of companies and trusts revisited

Author(s):  Dr Michael DIRKIS

This paper covers:

  • Review of recent cases focused on the key concepts
  • “Business carried on in Australia”  
  • Crown Insurance Services & Gebo Investments (Labuan)
  • Central management and control test (Milne v R & Garron  v R).
Materials from this session: