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Rethinking outbound structures in the light of the new CFC rules presentation


This presentation covers:

  • overview of key CFC provisions
  • financing structure- Current rules
  • financing structure- Proposed rules
  • impact of CFC reforms - Background.

Author profile

Peter Madden CTA
Peter leads KPMG’s International Tax Advisory group, with over 30 years’ experience providing taxation advisory services to a wide range of taxpayers. Peter specialises in corporate and international tax. Peter has been a member of the Taxation Institute since 1983 and is a member of the Chartered Accountants Australia and New Zealand. Peter has been very closely involved in Australia’s response to Base Erosion and Profit Shifting (“BEPS”) including being a member of the Treasury’s BEPS Tax Advisory Group and other Government forums aimed at ensuring that the Australian taxation base is not adversely impacted by BEPS or international tax changes triggered by BEPS. Peter liaises extensively with senior personnel from the Australian Taxation Office (“ATO”) to foster transparent and open dialogue between the industry, the profession and the ATO in order to facilitate efficient administration of tax collection in Australia and provide more certainty for businesses to operate in Australia. Peter has also been closely involved and has worked extensively with Treasury, the ATO and industry representatives in drafting new legislation relating to Australia’s International tax regime including the Investment Manager Regime, MAAL, Hybrids and Diverted Profits Tax. - Current at 04 February 2019
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This was presented at International Masterclass .

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