Published on 18 Sep 2013
| Took place at Daltone House Hyde Park, Sydney
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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Tax base erosion - Emerging and likely developments
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.
Legislative changes to the transfer pricing rules - The state of play
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.
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.
Managing GST and customs duty obligations for cross-border transactions
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.