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Where are we, how did we get here and where are we going? prsentation


This presentation covers:

  • set tone for the day – “it’s about the context”:
    • recent history, i.e. since 2001
    • current issues and developments
    • crystal ball gazing
  • not designed to analyse issues:
    • role of following presentations
  • focus on developments for corporates:
    • other fundamental changes for individuals, eg section 23AG, temporary residents etc
  • fundamental premise of international tax:
    • outbound – profits/gains from conduct of active foreign business with third parties not subject to Australian tax on:
      • derivation (CFC rules and section 23AH)
      • repatriation (section’s 23AJ and 23AH)
      • exit (AFBAP and section 23AH)
      • distribution to non-residents (CFI)
  • inbound – ensure an “appropriate” Australian sourced profits/gains subject to Australian tax:
    • transfer pricing
    • treaty model
    • capital gains on taxable Australian property.

Author profile

Mathew Chamberlain CTA
Mathew is a partner at EY and leads their Perth International Tax group. A legal practitioner admitted in WA and NSW, he has more than 27 years’ experience in international tax, focusing on the large multinational and corporate environments across Australia, the US, Europe, Asia-Pacific and Africa. Mathew specialises in international tax reform, foreign investment into Australia and outbound investment from Australia. A long-time member of The Tax Institute, Mathew has presented at numerous national and state conventions on international tax issues and has also lectured on tax law at the University of Western Australia and Curtin University. Mathew has led and participated in a number of government and ATO initiatives, working groups etc. on international tax law and policy issues affecting Australian inbound and outbound investment, including through the development of professional body and EY submissions on tax residency. - Current at 30 November 2020
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This was presented at International Tax Day .

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Individual sessions

Where are we, how did we get here and where are we going?

Author(s):  Mathew CHAMBERLAIN

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