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Cloud computing - Understanding the tax implications paper


E-Commerce and cloud computing are dominating discussion groups but what are the tax impacts for your business? This paper looks at the key tax issues arising from these arrangements now and in the future. Issues covered include:

  • source of income in an e-commerce environment
  • application of the permanent establishment concepts
  • characterising payment as for services or royalties
  • how e-commerce impacts upon residency.

Author profiles:

Frank Putrino ATI
Frank is a Director in KPMG's Global Transfer Pricing Services practice in Melbourne and has over 23 years of transfer pricing and international tax experience across both industry and professional service firms. As the former in-house Global Transfer Pricing Director & Counsel for a Fortune 100 MNC for 9.5 years, Frank was responsible for the design, development and implementation of transfer pricing strategy, policy, processes and documentation and controversy across the Americas, Europe and Asia Pacific regions. Prior to that, Frank was a Principal in a Professional Services Transfer Pricing team for 12.5 years. Frank has assisted a number of Australian and overseas based clients with their transfer pricing and global supply chain planning, compliance and controversy needs by bringing a wealth of operational and tax experience applied across diverse industries and jurisdictions. His experiences balance and recognize the synergies required among the business and tax teams, resulting in practical, commercial strategies that provide viable transfer pricing solutions to complex business challenges. Current at 14 August 2013 Click here to expand/collapse more articles by Frank PUTRINO.
Brendan Rynne
Brendan is a Partner in KPMG's Global Transfer Pricing Services practice based in Melbourne. Brendan has been at KPMG for 18 years, and has been a partner for 10 of those years. He currently advises various inbound and outbound MNE's on their related party dealings, and has had a particular focus on ENR, agricultural, manufacturing and distribution businesses. Brendan works on a range of transfer pricing activities, from compliance work to planning, APA's and dispute engagements. Prior to joining the GTPS practice, Brendan led the economics practice and was KPMG Australia's Chief Economist. Current at 14 August 2013

This was presented at Vic 1st Annual Tax Forum.

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