Published on 06 Feb 19
by NATIONAL DIVISION, THE TAX INSTITUTE
This presentation covers:
- banking landscape
- typical structures
- legal framework
- current areas of focus for the ATO
- insight from the tax avoidance taskforce (top 100 and top 1000 programs)
- RBA vs FSE in practice – is there much difference?
- what does this mean for taxpayers seeking assurance over branch attribution outcomes?
- scope for Australia adopting the FSE under the Authorised OECD approach.
Julian Pinson, FTI, is a Partner at Greenwoods & Herbert Smith Freehills Pty Limited. Julian advises on a wide range of tax matters, with a focus on banking and financial services, property, M&A and funds management. Julian has particular expertise in cross-border finance, TOFA, corporate restructures, debt and equity raisings and M&A.
- Current at
14 January 2021
James Campbell is a Director, managing
the Banking and Finance Strategy in the
Public Groups business line of the ATO.
James has over 15 years experience
in compliance, audit and public advice
with a focus on the banking and finance
industry. Areas of expertise include capital
management and hybrid financing,
offshore banking units (OBUs), branch
attribution, controlled foreign corporations
(CFCs), Part IIIB and thin capitalisation.
James is currently playing a leading role in
the delivery of the ATO’s Top 100 and Top
1,000 program in relation to the banking
and finance industry.
- Current at
01 November 2018