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International Tax Day

Published on 05 Aug 2014 | Took place at City West Receptions, WA , WA

Australia’s international tax landscape remains a focus. Some previously announced measures have been abandoned, some previously announced measures have been legislated or introduced to Parliament and it appears more change is on the horizon.

This event focused on where things currently stand on matters such as transfer pricing and thin capitalisation, whilst also having an eye to the future. It was a must attend event for taxpayers and advisers in the international tax space.

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

Individual sessions

Where are we, how did we get here and where are we going?

Author(s):  Mathew CHAMBERLAIN

This presentation covers:

  • set tone for the day – “it’s about the context”:
    • recent history, i.e. since 2001
    • current issues and developments
    • crystal ball gazing
  • not designed to analyse issues:
    • role of following presentations
  • focus on developments for corporates:
    • other fundamental changes for individuals, eg section 23AG, temporary residents etc
  • fundamental premise of international tax:
    • outbound – profits/gains from conduct of active foreign business with third parties not subject to Australian tax on:
      • derivation (CFC rules and section 23AH)
      • repatriation (section’s 23AJ and 23AH)
      • exit (AFBAP and section 23AH)
      • distribution to non-residents (CFI)
  • inbound – ensure an “appropriate” Australian sourced profits/gains subject to Australian tax:
    • transfer pricing
    • treaty model
    • capital gains on taxable Australian property.
Materials from this session:

BEPS: The future of Australian and international taxation or the end of the corporate income tax?

Author(s):  Richard J VANN

This paper covers:

  • what is the BEPS problem?
  • what are the likely outcomes of the action plan?
Materials from this session:

Government reforms to Australia’s international tax system

Author(s):  Michael BONA,  Peter COLLINS,  Nick Moore ,  Pratheeb Jeyaratnarajah

This paper covers:

  • thin capitalisation
  • exemption for foreign dividends
  • anti-avoidance rules
  • closing the loopholes for non-residents
  • section 25-90.
Materials from this session:

Self-assessment update: Draft transfer pricing documentation, penalties & reconstruction guidance from the ATO

Author(s):  Janelle Sadri

This paper covers:

  • new transfer pricing documentation requirements – subdivision 284-E TAA 1953
  • penalties – overview of PS LA 3672
  • the Commissioner’s broader powers of reconstruction – overview of TR 2014/D3
  • what should taxpayers do in this environment?
Materials from this session: