Published on 14 Jul 05
by WESTERN AUSTRALIAN DIVISION, THE TAX INSTITUTE
Over the last year, the Review of International Taxation has brought about a number of significant changes to the Australian international tax landscape.
Do you know what these changes are and how they would impact on your Australian based clients who are expanding their businesses offshore?
This paper will assist you to build up your knowledge of the new international tax provisions and it will also cover the following key practical issues:
- should your Australian based client set up a foreign branch or subsidiary?
- if it is a foreign subsidiary, how should it be structured?
- where should the offshore entity be located? - Possible tax haven jurisdictions
- should the shares be owned in the foreign country, the home country, or some third country?
- if there is intellectual property involved, what is the appropriate structure to hold this?
- repatriation of profits back to home country
- treatment of dividends received from foreign subsidiary by home parent company
- implications of CFC/FIF rules
- tax treaties
- implications of recent international tax reform measures - the New International Tax Arrangement (Participation Exemption and Other Measures) ACT 2004.
Marc is a Director with the boutique taxation practice, KD Johns & Co. He is a
Fellow of the Taxation Institute of Australia and a member of the Institute of Chartered Accountants. Marc has over nine years experience practicing in taxation, including six years with Andersen's Taxation Division in Perth. Marc provides strategic solutions to a wide range of clients on matters including international tax, tax consolidation, tax reform, property taxation, mergers and acquisitions, capital gains tax and GST
Current at 27 March 2008 Current at 18 April 2008
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