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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 Ernst and Young and leads the International Tax group for Perth. He is a legal practitioner with over 22 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 and foreign investment inbound and outbound from Australia. He is a frequent presenter with The Tax Institute and has spoken at both the National and State Conventions on international tax. He is also the WA representative on the Institutes International Tax subcommittee. In addition, Mathew is a seasoned lecturer in tax law at the University of Western Australia and Curtin University, at both postgraduate and undergraduate level. - Current at 08 October 2015
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This was presented at International Tax Day .

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

Author(s):  Mathew CHAMBERLAIN

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