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Government reforms to Australia’s international tax system paper


This paper covers:

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

Author profiles

Michael Bona CTA
Michael is a corporate tax adviser at PwC with over 13 years experience advising Australian and foreign multinational companies on the tax aspects of their businesses, specialising in cross-border transactions, financing and M&A in the resources sector. Michael holds a Bachelor of Laws (with Hons) from the University of Queensland and Masters of Laws from the University of Melbourne. He is admitted to practice in Queensland, Victoria and Western Australia. - Current at 18 August 2016
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Peter Collins FTI
Peter Collins, FTI, is a Partner at PwC with 25 years experience as a specialist in global tax, assisting foreign investors structuring their Australian investments and Australian corporates expanding offshore. He works with the firm’s global tax network to develop solutions for clients and is a member of the International Tax executive, which allows him to provide a unique global perspective. He is a consultant to Treasury in relation to tax reform in the areas of international tax and transfer pricing, including the MAAL/DPT and a member of the Treasury’s BEPS Tax Advisory Group. Peter was heavily involved in the rewrite of the Australian transfer pricing rules; he appeared before the Senate Estimates Committee to object to the retrospective application of those rules to US companies. He represented PwC before the Senate inquiry in relation to corporate tax avoidance by multinational companies. - Current at 01 November 2018
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Nick Moore
Nick is a Senior Consultant with PwC.
Current at 1 August 2014
Pratheeb Jeyararnarajah
Jeyaranarajah is a Manager with PwC. - Current at 01 August 2014


This was presented at International Tax Day .

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

Author(s):  Mathew CHAMBERLAIN

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