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  • International Masterclass

International Masterclass

Published on 18 Sep 2013 | Took place at Daltone House Hyde Park, Sydney, NSW

    This series of papers, presented by leading international tax experts, provides you with an understanding of the continuing changes in the international tax arena. They consist of detailed presentations and discussions of recent changes and developments, with a focus on the practical impact of such changes and the commercial issues that arise.
    Topics covered include:
  • the global legislative reactions to tax base erosion
  • a review of the legislative changes to the transfer pricing rules and of the practical implications that flow from these changes
  • a review of the structural changes to international tax, particularly on thin capitalization and its interface with other changes and provisions
  • a practical consideration of debt deductions and their calculation, following on from the removal of section 25-90
  • capital gains and non-residents
  • tax residency status of individuals and implications for corporates boards.

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Individual sessions

Tax base erosion - Emerging and likely developments

Author(s):  Richard J VANN

OECD governments (including the Australian Government) have committed to stepping up their efforts to tackle the perceived problems of tax base erosion and profit shifting by multinationals. A number of significant developments are taking place in the international sphere to address these issues. It is important that taxpayers understand the possible implications that these developments may have for their organisations in the medium to long term.

This paper examines:

  • the recent initiatives of the OECD, the G8 and the G20
  • how Australia and other countries are proposing to tackle the perceived problem, including through measures requiring the disclosure of tax information by taxpayers under the rubric of transparency.
Materials from this session:

Legislative changes to the transfer pricing rules - The state of play

Author(s):  Geoff GILL

Australian transfer pricing laws have undergone their most radical change in 30 years and it will impact every Australian multinational. This paper provides an overview of the background and drivers for the legislative changes, and an overview of the key changes and implications for MNCs.

It covers:

  • background and drivers for change in the Australian transfer pricing legislation
  • relevance and interaction between Division 13, s815-A and the new s815-B and s815-C laws
  • key aspects of the new legislation, including application of the arm’s length principle, relevance of economic substance and ATO reconstruction powers, and requirements for transfer pricing documentation
  • implications for MNCs historical and future transfer pricing positions
  • treaty partner considerations and dispute resolution mechanisms.
Materials from this session:

Legislative changes to the transfer pricing rules - The practical implications

Author(s):  Tony Gorgas

This presentation covers the key practical implications from the changes in the transfer pricing rules, and actions that may be required by taxpayers including:

  • practical examples of how the new laws will apply, focusing on business restructures, intra-group financing and loss making subsidiaries
  • taxpayer profiles and "trigger transactions" impacted by the legislative changes
  • ATO transfer pricing audit focus areas
  • impact on disclosures on the International Dealing Schedule.
Materials from this session:

Australian legislative responses to the BEPs report - The changes so far and what you should be thinking about!

Author(s):  Ernest Chang,  Rosalind MYINT,  Arash AZIMI

This paper covers:

  • thin capitalisation changes - safe harbour and worldwide gearing
  • the arm’s length debt test - status update
  • refinancing to manage thin capitalisation changes - the tips and traps!
  • the interface of thin capitalisation, s25-90 and s23AJ and the status of NANE income
  • transparency changes
  • the repeal of s25-90 – what apportionment, allocation or tracing issues will arise.
Materials from this session:

Managing GST and customs duty obligations for cross-border transactions

Author(s):  Andrew Cavenor,  Marc Bunch

The GST obligations arising in respect of cross-border transactions can be complicated. In addition, there are customs duty implications that can arise in circumstances that may not be obvious. This paper explores the tricks and traps around these matters and will discuss market trends for the management of these issues, including:

  • recent GST cases and developments in the cross-border transaction context
  • why customs duty is important and when it can arise
  • recent advancements in technology that groups can use to manage their obligations.
Materials from this session:

Non-residents and capital gains

Author(s):  Philip BISSET,  Mark FRIEZER,  Antony BARRIER,  Shane Tan

This paper covers key developments and things to watch out for including:

  • an overview of the operation of Div 855
  • changes to the ''principal asset'' test in Subdiv 855-A
  • removal of discount for non-resident individuals
  • introduction of a 10% non-final withholding tax to the disposal by foreign residents of certain taxable Australian property
  • other methods of recovery of alleged tax
  • likely impact of the decision in Resource Capital Fund
  • implications of upstream non-Australian transfers changing the underlying indirect ownership
  • the impact of landowner stamp duty regimes.
Materials from this session:

Establishing residence for global villagers

Author(s):  Ian STANLEY

The residence of individuals, and in particular severance of and/or adoption of a tax residence, has become a real issue over the last 3 years with a significant focus being directed towards it.

This paper covers:

  • what are the key issues
  • has the ATO position moved?
  • what have the recent cases said?
  • are there any apparent critical features that will change status?
  • what messages need to be reaching board level?
Materials from this session: