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Renovating the CFC and FIF regimes and rethinking outbound structures paper


This paper covers:

  • explanation of proposals
  • aspects of the ed on CFCS requiring further consideration and review
  • rethinking current structures.

Author profiles

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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Peter Madden CTA
Peter leads KPMG’s International Tax Advisory group, with over 30 years’ experience providing taxation advisory services to a wide range of taxpayers. Peter specialises in corporate and international tax. Peter has been a member of the Taxation Institute since 1983 and is a member of the Chartered Accountants Australia and New Zealand. Peter has been very closely involved in Australia’s response to Base Erosion and Profit Shifting (“BEPS”) including being a member of the Treasury’s BEPS Tax Advisory Group and other Government forums aimed at ensuring that the Australian taxation base is not adversely impacted by BEPS or international tax changes triggered by BEPS. Peter liaises extensively with senior personnel from the Australian Taxation Office (“ATO”) to foster transparent and open dialogue between the industry, the profession and the ATO in order to facilitate efficient administration of tax collection in Australia and provide more certainty for businesses to operate in Australia. Peter has also been closely involved and has worked extensively with Treasury, the ATO and industry representatives in drafting new legislation relating to Australia’s International tax regime including the Investment Manager Regime, MAAL, Hybrids and Diverted Profits Tax. - Current at 04 February 2019
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This was presented at International Masterclass .

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Individual sessions

Renovating the CFC and FIF regimes - Where are we at?

Author(s):  Alison RODI

Materials from this session:

IBM on withholding - What it means

Author(s):  Simon THORP,  Erin Saunders

Materials from this session:

Reportable tax positions

Author(s):  Miquel P. TIMMERS

Materials from this session:

Further details about this event:


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