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The residence of companies and trusts revisited paper

Published on 17 Oct 12 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This paper covers:

  • Review of recent cases focused on the key concepts
  • “Business carried on in Australia”  
  • Crown Insurance Services & Gebo Investments (Labuan)
  • Central management and control test (Milne v R & Garron  v R).

Author profile:

Author Photo - Michael Dirkis CTA
Prof Michael Dirkis CTA
Michael is Professor of Taxation Law at the University of Sydney. He has a PhD on Australian international taxation and is a noted researcher, having authored Is it Australia's? Residency and Source Analysed (2005, Australian Tax Research Foundation), as well as authoring and co-authoring over 590 publications and papers. From May 1999 until October 2009 he was, as Senior Tax Counsel for the Taxation Institute, in the forefront of the all major tax reform and taxation administration reforms. He continues his involvement as a member of the Treasury's Tax Treaties Advisory Panel and the Education Committee of the Tax Practitioners Board. He was awarded the Australasian Tax Teachers Association's Graham Hill medal in recognition of his "outstanding contribution to the teaching of taxation law and policy" on 21 January 2010. Current at 29 October 2012 Click here to expand/collapse more articles by Dr Michael DIRKIS.
 

This was presented at International Masterclass 2012.

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Individual sessions

Practical implications arising from changes to the Australian transfer pricing legislation

Author(s):  Paul BALKUS

Materials from this session:

Exchange of and access to information

Author(s):  Michael O'NEILL,  David ALLEN

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