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Australian taxation issues for outbound resources companies paper
Published on 15 Oct 14 by WESTERN AUSTRALIAN DIVISION, THE TAX INSTITUTE
This paper covers:
- base erosion and profit shifting (BEPS) – setting the scene
- thin capitalisation for outbound investors
- dividend participation exemption
- controlled foreign companies and Section 25-90
- practical considerations.
Author profiles:
Matt PalmerMatt is a Consultant with PwC.
Current at 1 September 2014
Sara Mattsson
Sara is a Director in PwC’s Perth Corporate Tax team specialising in oil and gas and international tax. Sara has over 12 years tax experience and has spent time working in professional services firms in London, Bangkok and Melbourne. Prior to joining PwC, Sara was the Australian Tax Manager of an Asian multinational oil and gas company where she was responsible for all taxes related to the Australian group including evaluation of potential investments into Australia. Sara’s client base includes multinationals investing into the Australian resources sector as well as Australian outbound corporates. Sara’s international tax experience has included advising clients on significant inbound and outbound acquisitions and divestments, including funding structures. Sara also has significant experience advising clients on resources-specific tax issues including Petroleum Resource Rent Tax (PRRT) and exploration/first-use. Current at 07 October 2014Stuart Landsberg FTI
Stuart is a partner specialising in international tax and the energy and resources industry. He has over 10 years experience focusing on the resources industry, including three years in PwC’s Sydney office advising clients on the tax implications of inbound and outbound investment. Stuart is a member of the firm’s Australian international tax and energy and resources focus groups and regularly contributes to the firm’s thought leadership in both areas. Current at 11 April 2016
Click here to expand/collapse more articles by Stuart Landsberg.
Scott Reid
Scott is a Senior Consultant with PwC.
Current at 1 September 2014
This was presented at 2014 National Resources Tax Conference.
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Individual sessions
Shifting trends in the global and Australian outlook
Author(s): Scott HaslemMaterials from this session:
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Base erosion & profit shifting
Author(s): Alf CAPITOMaterials from this session:
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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
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Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
Infrastructure support for resources companies – Structures and tax issues
Author(s): Brett GreigMaterials from this session:
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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
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Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
Primer of important mining law concepts
Author(s): Lorenzo PacittiMaterials from this session:
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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
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Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
Taxation of non-resident investors on exit from Australia
Author(s): Melanie BAKERMaterials from this session:
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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
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Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
Tax and native title - Current taxation issues affecting native title groups and Indigenous organisations in 2014
Author(s): Adam LEVIN, Fleur LewisMaterials from this session:
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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
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Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
Capitalising the boom: Issues faced by mining and E&P companies with the capital allowances regime
Author(s): Peter Hyman, Ben OPIEMaterials from this session:
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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
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Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
Financing resource projects
Author(s): Martin FRYMaterials from this session:
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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
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Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
Current issues in M&A
Author(s): Nick HEGGART, Tristan Boyd, Daniel TaborskyMaterials from this session:
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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
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Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
Public infrastructure industry & policy landscape
Author(s): Paul LAXON, Mark WhiteMaterials from this session:
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Important petroleum law concepts
Author(s): Tracey GreenawayMaterials from this session:
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Australian taxation issues for outbound resources companies
Author(s): Stuart Landsberg, Sara Mattsson, Matt Palmer, Scott ReidMaterials from this session:
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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
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Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
Project pools
Author(s): James MACKY, Praneel NandMaterials from this session:
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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
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Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
Income tax and exploration expenditure - An ATO view on the current state of play
Author(s): Glenn DAVIESMaterials from this session:
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A new era in transfer pricing
Author(s): Jacques Van RhynMaterials from this session:
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Tax consolidation – Practical issues in the current law
Author(s): Narelle MCBRIDE, Ryan Leslie , Ken SPENCEMaterials from this session:
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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
shopping_cart Add all items to cart - $72.00
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
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