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Australia's new participation exemption (768-A) presentation

Published on 26 Nov 14 by VICTORIAN DIVISION, THE TAX INSTITUTE

This presentation covers:

  • why change the rule in the shadow of BEPS?
  • new Subdivision 768-A and contrast with old section 23AJ
  • what now works and what doesn't
  • Part IVA considerations.

Author profile:

Peter Collins FTI
Peter has 25 years experience as a specialist in global tax, assisting foreign investors structuring their Australian investments and Australian corporates expanding offshore. He works with the firm’s global tax network to develop solutions for clients. Peter is recognised for his practical experience with international tax issues. He is a consultant to Treasury in relation to tax reform in the areas of international tax, including CFCs, debt-equity, thin capitalisation, non-resident CGT and the Australian diverted profits tax. Peter is a member of the Australian Treasury’s BEPS Tax Advisory Group. Peter was heavily involved in the rewrite of the Australian transfer pricing rules; he appeared before the Senate Estimates Committee to object to the retrospective application of those rules to US companies. He represented PwC before the Senate inquiry in relation to corporate tax avoidance by multinational companies. Current at 14 July 2016 Click here to expand/collapse more articles by Peter COLLINS.
 

This was presented at Thin Capitalisation and Cross Border Financing - Changes Enacted.

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Individual sessions

Thin capitalisation and foreign resident CGT changes

Author(s):  Peter Janetzki

Materials from this session:

Worldwide gearing test

Author(s):  Claudio Cimetta

Materials from this session:

Australia's new participation exemption (768-A)

Author(s):  Peter COLLINS

Materials from this session:

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