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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
Stuart Landsberg FTI
Stuart is a Partner in PwC’s Brisbane office specialising in international tax and the energy and resources industry. He has over 11 years experience focusing on the resources industry, including 3 years in PwC’s Sydney office advising clients on the tax implications of inbound and outbound investment with a particular focus on financing and holding structures. Stuart is a member of PwC’s Australian international tax and energy and resources focus groups and regularly contributes to PwC’s thought leadership in both areas. - Current at 30 April 2019Sara 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 2014Matt Palmer
Matt is a Consultant with PwC.Current at 1 September 2014
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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Shifting trends in the global and Australian outlook
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Base erosion & profit shifting
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Infrastructure support for resources companies – Structures and tax issues
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Taxation of non-resident investors on exit from Australia
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Capitalising the boom: Issues faced by mining and E&P companies with the capital allowances regime
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Financing resource projects
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Current issues in M&A
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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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Project pools
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A new era in transfer pricing
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