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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.