Over the last year, the Review of International Taxation has brought about a number of significant changes to the Australian international tax landscape.
Do you know what these changes are and how they would impact on your Australian based clients who are expanding their businesses offshore?
This paper will assist you to build up your knowledge of the new international tax provisions and it will also cover the following key practical issues:
- should your Australian based client set up a foreign branch or subsidiary?
- if it is a foreign subsidiary, how should it be structured?
- where should the offshore entity be located? - Possible tax haven jurisdictions
- should the shares be owned in the foreign country, the home country, or some third country?
- if there is intellectual property involved, what is the appropriate structure to hold this?
- repatriation of profits back to home country
- treatment of dividends received from foreign subsidiary by home parent company
- implications of CFC/FIF rules
- tax treaties
- implications of recent international tax reform measures - the New International Tax Arrangement (Participation Exemption and Other Measures) ACT 2004.