Published on 18 Sep 08
by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE
This presentation covers:
- overview of Australian Entities
- overview of Foreign Hybrid Rules
- classification of Foreign Entities
- application of Foreign Hybrid Rules - Current Issues
- how is a fiscally transparent entity (FTE) treated under double tax agreements?
- is income derived by or through a FTE eligible for benefits under a DTA?
- what are the issues on the application of DTAs to FTEs?
- the OECD view
- global responses
- the Australian position(?)
- case studies.
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
David Watkins, CTA, is the partner-incharge of the Deloitte Australia Tax Insights & Policy group. David has over 30 years experience in corporate income tax and international tax covering a wide range of tax issues across various industry sectors. David has worked in Malaysia, Singapore and New York.
- Current at
31 October 2019