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Coping with the cross-border attack: The MAAL and more

Published on 01 Mar 17 by "THE TAX SPECIALIST" JOURNAL ARTICLE

Australia’s multinational anti-avoidance law (MAAL) was introduced to “counter the erosion of the Australian tax base by multinational entities”. This article explores the nature of Australia’s attack on the cross-border transactions of multinational enterprises (MNEs) under the MAAL. It explains the key relevant statutory provisions of the MAAL and where this law sits in relation to the broader international tax framework which the government has committed to shape. It explores how MNEs may be similarly impacted by the new diverted profits tax measures, which was recently introduced into parliament and will commence on 1 July 2017. It describes a field of study which can help explain how and why the ATO has announced that it is reviewing many more taxpayers than were initially described by the government as targets of the law.

Author profiles

Peter Collins FTI
Peter Collins, FTI, is a Partner at PwC with 25 years experience as a specialist in global tax, assisting foreign investors structuring their Australian investments and Australian corporates expanding offshore. He works with the firm’s global tax network to develop solutions for clients and is a member of the International Tax executive, which allows him to provide a unique global perspective. He is a consultant to Treasury in relation to tax reform in the areas of international tax and transfer pricing, including the MAAL/DPT and a member of the Treasury’s BEPS Tax Advisory Group. Peter was heavily involved in the rewrite of the Australian transfer pricing rules; he appeared before the Senate Estimates Committee to object to the retrospective application of those rules to US companies. He represented PwC before the Senate inquiry in relation to corporate tax avoidance by multinational companies. - Current at 01 November 2018
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Greg Weickhardt
Greg Weickhardt is a PwC Global Tax Partner specialising in advising multinational businesses, with a focus on aligning tax and transfer pricing arrangements with business operating models. Greg has previously worked in Europe, Asia and the Americas. Most recently Greg has been working with multinational companies to navigate the consequences of competing interpretations of the arm’s length principle within the digital economy. - Current at 16 December 2020

 

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