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Diverted Profits Tax and MAAL – how and when they apply and how to manage disputes paper

Published on 24 Aug 17 by QUEENSLAND DIVISION, THE TAX INSTITUTE

This paper covers:

  • Australian revenue concerns with taxation of multinational corporations
  • significant global entities (SGEs)
  • diverted profits
  • multinational anti avoidance law
  • case study - would the DPT have applied to Chevron facts if applicable at the time?
  • anticipated ATO approaches to DPT reviews
  • managing risk and preparation for DPT controversy.

 

Author profiles

Anthony Portas CTA
Anthony is a Tax Partner at MinterEllison, and has more than 25 years experience in corporate and international tax, with a strong focus in the energy, resources, property and infrastructure sectors. He has deep knowledge and technical expertise in all aspects of corporate taxation, including international, M&A, transfer pricing and tax risk management. Anthony was previously the Head of Tax, Asia Pacific for the mining group Anglo American pIc. Prior to that, he was a senior tax manager at a Big Four accounting firm. Anthony has had extensive involvement in both federal and state tax matters, both at a technical and policy level. He was a previous Chairman of the Minerals Council of Australia Tax Committee and an Executive Committee member of the Corporate Tax Association. - Current at 21 February 2018
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Daniel Slater CTA
Daniel is a Senior Associate in the Tax Controversy practice at Maddocks in Melbourne. Daniel advises SMEs, large corporates and multinational enterprises in respect of their tax risks, tax audits and disputes with a particular focus on alternative dispute resolution. Daniel has expertise in the conduct of tax controversy in respect of all aspects of income tax, GST, transfer pricing and cross-border matters. Daniel has also acted for the ATO in litigation in the Administrative Appeals Tribunal, Federal Court and Full Federal Court. - Current at 01 January 2015
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This was presented at 2017 Queensland Tax Forum .

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Individual sessions

M&A update: A selection of topical issues

Author(s):  Michael CHANG

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Purpose – What Does it Mean?

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Practical approaches to working with startups

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State taxes update

Author(s):  Philip MAGOFFIN

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ATO - Achieving certainty

Author(s):  Joanne CASBURN,  Anthony Bach

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