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Foreign entity classification in an outbound investment context and Double tax agreements and fiscally transparent entities presentation


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.

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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David Watkins CTA
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
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This was presented at International Tax Masterclass .

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Individual sessions

Sharp edges in a modular world

Author(s):  Ian STANLEY

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