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  2011

International tax structuring - Back to basics: Source, revenue or capital, treaty shopping

Source: Victoria

Published Date: 9 Feb 2011

 
This event focused on whether the boundaries of "legitimate' international tax planning have shifted following the TPG/Myer case and the much awaited release of the Australian Taxation Offices ("ATO") view on this matter in the form of Taxation Determinations TD 2010/20, TD 2010/21, TD 2010/D7 and TD 2010/D8 (the Rulings). In addition, the ATO was granted a freezing order against Resource Capital Fund III LP in November 2010. This event covered:
  • impact of the TPG/Myer case and the rulings
  • what types of "treaty shopping' will be caught by Part IVA having regard to the ATO's views in TD 2010/20?
  • the global trend against treaty shopping - increased crossborder co-operation, exchange of information imitation amongst tax authorities and substance requirements
  • is cross-border tax structuring an endangered art?
  • other weapons in the ATO's arsenal
  • recent announcements relating to foreign managed funds and collective investment vehicles.

International tax structuring - Back to basics: Source, revenue or capital, treaty shopping

Author(s): Peter Collins
Materials from this session:

Details

  • Published On:9 Feb 2011
  • Took place at:RACV Club, Melbourne

The material is copyright. Apart any fair dealing for the purpose of private study,

research critisism or review, as permitted under the copyright Act, no part may be rerpoduced by any process without written permission from The Tax Institute.

Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

This material is copyright. Apart from any fair dealing for the purpose of private study., research, critisism or review, as permitted under teh copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.

Unless expressly stated, opininons are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

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2011

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