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International Taxation: Australia - From the outside looking in paper


This paper considers some of the income tax issues relevant to structuring these investments and recent developments in Australia's international taxation system.

Topics covered in this paper include:

  • Methods to repatriate profits from Australia
  • Withholding tax issues
  • Thin capitalisation provisions
  • Debt / equity rules
  • Existing CGT & DTA issues for non-residents 

Author profile

Aldrin De Zilva CTA
Aldrin is the Head of Projects and Infrastructure at Greenwoods & Herbert Smith Freehills and has over 20 years experience in a specialist taxation role. He acts predominantly for large multinational and Australian listed companies and has significant experience in advising both vendors and purchasers in multi-billion dollar infrastructure projects. As well as providing taxation advice, Aldrin has been the instructing solicitor on a number of matters before the Federal Court and High Court of Australia. Aldrin has been recognised as one of Australia’s leading tax controversy advisers by the International Tax Review and is heavily involved in consultations regarding taxation law reforms, including assisting the Board of Taxation. Aldrin is a Senior Fellow at the University of Melbourne and lectures in the Masters of Taxation program. - Current at 24 January 2017
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This was presented at International Taxation: Australia - From the outside looking in .

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