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Now that we're global - managing taxation of international profits paper

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Published on 17 Sep 13 by QUEENSLAND DIVISION, THE TAX INSTITUTE

This paper examines Australia’s CFC regime and profit repatriation in more detail, including:

  • overview of Australian CFC regime
  • common traps including tainted services and tainted sales income
  • proposed reforms to the CFC regime
  • foreign withholding taxes on profit repatriation – does this result in tax leakage?
  • overview of conduit foreign income and impact on resident and non-resident investors.

Author profile

Muhunthan Kanagaratnam CTA
Muhunthan leads the tax practice of Gilbert + Tobin. Muhunthan was formerly a Special Counsel of G+T and an M&A – Tax Partner with Deloitte. He specialises in corporate transactions, including acquisitions, sales, IPOs and privatisations, where FIRB’s tax conditions often come into play. Muhunthan has advised on landmark transactions and managed tax disputes, both with significant tax exposures, and brings diverse experiences to his presentations for the Tax Institute. - Current at 04 September 2019
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This was presented at Expanding Private Business Day 3 - Going Global .

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