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Are all of your overseas subsidiaries really non-residents? paper

Published on 21 Sep 17 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This paper covers:

  • the Bywater decision
  • carrying on a business in Australia
  • is ‘central management and control’ controlled by shareholders who are residents of Australia
  • practically demonstrating central management and control and the ATO administrative approach.

Author profiles

Bianca Wood
Bianca is a Tax Director in PwC's Sydney office. Bianca has over 9 years’ experience advising domestic and multinational companies on a range of complex transaction-based issues including financing, acquisitions, disposals and internal group reorganisations. - Current at 25 October 2017
Sarah Hickey
Sarah is a Director in Corporate taxes at PwC. Sarah advises Australian and international businesses on structuring and implementing sale transactions, and has experience in acting for both vendors and purchasers. Sarah also has extensive experience in leading tax due diligence processes. She is also a qualified legal practitioner. - Current at 01 January 2014
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This was presented at Move to the Front on International Tax Matters .

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Individual sessions




International issues arising - Employee share plans

Author(s):  Sandra BUTH,  Richard WILSON

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Diverted profits tax

Author(s):  Jarrod Thomas,  Alia Lum,  Nick Maley

Materials from this session:

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