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Outbound investment issues paper

Published on 27 May 21 by QUEENSLAND DIVISION, THE TAX INSTITUTE

This paper covers:

  • Tax residency for foreign subsidiaries
  • Controlled foreign company (CFC) rules
  • Repatriation – taxation of dividends, conduit foreign income, withholding taxes
  • Foreign hybrid and anti-hybrid rules
  • Disposal – active foreign business assets percentage (AFBAP).

Author profile

Paul Mills
Paul worked in the PwC corporate tax practice for 20 years, for the main part focusing on mining and energy clients. In his last seven years at PwC, Paul ran the national tax education program, which has allowed the development of technical expertise in a broad range of corporate tax matters. Paul is now operating a tax consulting business of his own, Paul Mills Consulting Pty Ltd. - Current at 24 July 2019
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This was presented at 2021 Queensland Tax Forum .

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