Published on 10 May 13
by WESTERN AUSTRALIAN DIVISION, THE TAX INSTITUTE
This presentation provides a general overview of the key international tax considerations for foreign investors contemplating investment into Australia and also Australian corporations expanding their investments overseas. With the Government’s focus on international tax reform, this presentation covers some of the critical Australian taxation areas which need to be addressed in operating in a global market, including:
- basic structuring considerations
- financing considerations (incl. thin cap/TP, withholding taxes and hybrid financing)
- profit flow considerations to provide returns to investors (incl. foreign dividend/branch profits exemptions\
- withholding taxes and CFI)
- future exit from the investment (incl. participation exemption, non-resident CGT and source)
- other (incl. FITOs, CFC rules, treaty overlay).
Zubin is an Account Director with Deloitte who specialises in advising on International Tax issues relating to inbound and outbound Australian investment. Zubin has extensive experience advising clients (particularly in the Energy & Resources industry) on M&A transactions and international structuring issues, including tax effective financing and profit repatriation, treatment of foreign source income, application of tax treaties, cross-border leasing and Australia's controlled foreign company rules.
- Current at
23 June 2016
Kenneth is an Assistant Commissioner in the ATO's Tax Counsel Network. Prior to joining the ATO, he spent over 14 years working in public practice where he provided tax advisory and compliance assistance to a diverse client base. Kenneth's experience encompasses advising on corporate and international tax, restructures, mergers and acquisitions, financing and capital management transactions. He has also worked extensively in the areas of tax audits/reviews, rulings, cooperative compliance, tax law policy and design advocacy, and managing tax controversies and disputes.
- Current at
16 August 2016