Published on 17 Apr 07
by VICTORIAN DIVISION, THE TAX INSTITUTE
This paper focusses on Australia's non-resident tax initiatives and considers how the rules operate to benefit corporate and non-corporate taxpayers alike. Issues covered include:
- non-resident CGT rules: what CGT assets remain within Australia's tax net? Ongoing relevance of income / capital distinction? Reconciling domestic law with Australia's DTAs. Practical inbound structures for non-residents
- temporary resident rules: Who qualifies? What income is concessionally taxed? In what circumstances?
- conduit foreign income rules: How they operate? How non-resident stakeholders benefit? How resident Australian companies benefit?
- other favourable international tax initiatives (23AJ, 23AH, CGT relief for active foreign companies, CFC & FIF changes).
Current at 25 June 2009
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