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The attribution of income, losses and outgoings to foreign permanent establishments of Australian banks presentation

Published on 13 Feb 13 by NATIONAL DIVISION, THE TAX INSTITUTE

This presentation covers:

Australian outbound perspectives:

  • the domestic law framework: s 23AH, FITO rules and withholding tax rules
  • relevance of tax treaties and OECD guidelines to the attribution of profits to a foreign branch
  • the effect of intra-entity dealings (Max Factor decision, ATO rulings, treatment of intra-entity risk transfers)
  • Australian implications of capital attribution rules in foreign jurisdictions
  • what difference would adopting a functionally separate entity approach make?

Australian inbound perspectives:

  • the tax classification of the Australian branch
  • the recognition of intra-entity dealings
  • interaction between domestic rules and treaties
  • potential interaction with other rules, especially thin capitalisation and withholding tax
  • potential alternatives and approaches adopted in other jurisdictions.

Author profile:

Ian FULLERTON

Click here to expand/collapse more articles by Ian FULLERTON.
 

This was presented at 2013 Financial Services Tax Conference .

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Individual sessions

Topical tax treaty issues for the financial sector

Author(s):  Richard J VANN

Materials from this session:



Emerging regional issues (funds management)

Author(s):  Daryl CHOO,  Brian CHAMBERS

Materials from this session:


Australian Taxation Office audits, risk identification, dispute

Author(s):  Ashley KING,  Andrew MCLOUGHLIN

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GST and RITCs on trustee services

Author(s):  Amelia O'Rourke,  Bill PACKWOOD

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New R&D regime in financial services

Author(s):  Jamie MUNDY

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The promoter penalty regime - How the ATO ia applying it in practice

Author(s):  Bruce COLLINS,  Nathan FIRTH

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