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Foreign entities – Characterisation and treatment for Australian tax purposes paper


This is a continuing area of uncertainty as new foreign entities emerge. This paper covers:

  • characterisation of foreign entities: Partnership vs. Company
  • foreign hybrids - recent hot topics
  • OECD guidance regarding fiscally transparent entities (FTE's)
  • recent double tax treaty treatments of FTE's
  • case studies to illustrate the issues.

Author profiles

David Watkins CTA
David Watkins, CTA is the leader of the Deloitte Australia Tax Insights & Policy group. David has over 25 years’ experience and has worked in Malaysia, Singapore and New York. In his current role, David’s focus is on emerging tax developments and in particular, the Australian tax reform debate and the international process addressing Base Erosion & Profit Shifting (BEPS). The Tax Insights & Policy group is involved at various stages in these emerging issues including consultation and submissions, publications and presentations and assessing the impacts of tax law changes. - Current at 21 October 2016
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Alyson Rodi ATI
Alyson is a Tax Partner at Deloitte in Sydney specialising in International and Corporate Tax. Alyson has over 20 years experience advising clients on inbound and outbound cross-border transactions including tax-effective cross-border financing and profit extraction strategies, the application of double tax treaties, the applicability of Australia's foreign accruals rules and potential foreign tax issues. In addition to Alyson's extensive Australian experience, Alyson also has experience working in the international tax groups of Deloitte's London and Dublin offices and working for a major London law firm. - Current at 29 January 2015
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This was presented at International Tax Masterclass .

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Sharp edges in a modular world

Author(s):  Ian STANLEY

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