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The expanding offshore client


Australia’s tax system contains complex rules for Australian entities that wish to expand offshore. The rules can be a minefield and often present difficulties for tax advisers, particularly where they involve applying Australian tax concepts in foreign jurisdictions. This article is intended to provide an overview of the different rules that can apply to Australian entities expanding offshore. While the focus of the article is on offshore investments via a corporate entity, specific issues regarding investments through non-resident trusts are also discussed. The article opens with discussion of basic concepts, including residency and types of entity. The article then discusses in detail what is involved in expanding offshore through a corporate entity, including discussion of the CFC rules. The article concludes with a briefer examination of expansion offshore through a trust.

Author profile

Cameron Blackwood ATI
Cameron brings more than a decade of transactional tax expertise to his role as Director in Greenwoods & Herbert Smith Freehills’ Sydney office. He specialises in advising clients on the tax complexities of mergers, acquisitions and restructures, including cross-border issues and all aspects of employee share schemes, and regularly works in close collaboration with Herbert Smith Freehills. After joining Greenwoods & Herbert Smith Freehills as a graduate in 2004, Cameron built his corporate experience advising companies on a wide range of advisory and compliance matters, including a secondment to BHP Billiton. His industry knowledge is broad and includes the mining, real estate and financial services sectors. Cameron is a member of The Tax Institute’s Large Business and International Committee and the NSW Technical Committee. He holds a Bachelor of Business (Hons) and Bachelor of Laws (Hons) from the University of Technology Sydney, and a Master of Taxation from the University of Sydney. Cameron is admitted as a solicitor in New South Wales. - Current at 30 November 2020
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