101-110 of 139 results

Treasury consultation paper flags changes to stapled structures
Insight 28 Mar 2017

Stapled structures have been used as an investment platform in the property and infrastructure sectors for decades and more recently have been deployed into renewable energy agriculture and other areas Through the issue of its Taxpayer Alert on stapled structures on 31 January 2017 the ATO indicated ...

The new corporate collective investment vehicle: Wholesale application?
Insight 07 Sep 2017

This Insight considers whether the new Corporate Collective Inestment Vehichle is likely to replace the unit trust as the vehicle of choice for wholesale (as opposed to retail) fund structures. ...

Exposure draft legislation for Australian 'hybrid mismatch rules' released
Insight 01 Dec 2017

Treasury has released for consultation exposure draft legislation to introduce new rules to neutralise the effects of hybrid mismatch arrangements in accordance with Action Item 2 of the OECDG20 Base Erosion and Profit Shifting Project Multinational groups with cross-border arrangements or proposing ...

Land tax recovery - no, yes, no again
Insight 15 Jun 2017

The Queensland Government is proposing legislation that will restore a prohibition on landlords requiring tenants to pay land tax under commercial leases entered into after 1 January 1992 and before 30 June 2009 This essentially negates the effect of a Supreme Court decision that land tax from 30 ...

Positive guidance on negative control?
Insight 18 Sep 2015

Draft guidance targeting the infrastructure industry particularly in the context of stapled property trust and operating company structures frequently used in infrastructure projects has been released Partner Charles Armitage Managing Associate Judith Taylor and Lawyer David Lewis report ...

Withholding tax on the sale of Australian property by foreign residents exposure draft legislation released
Insight 28 Jul 2015

Exposure draft legislation implementing the Federal Governments promise to introduce a 10 per cent non-final withholding tax on purchasers of certain types of taxable Australian property by foreign residents has been released for review and comment Partner Charles Armitage and Associate Scott Lang ...

Landholder duty risks associated with international transactions surface in Crocodile Gold case
Insight 17 Jun 2015

Corporate mergers and acquisitions commonly involve changes to entities that comprise a corporate group the holding of property within that group and the ultimate beneficial ownership of that group Even if those changes occur entirely outside Australia Australian landholder duty may be payable and ...

Australia's new Multinational Anti-avoidance Law moves ahead of OECD consensus
Insight 14 May 2015

The Government has announced as part of the Budget that it will introduce a new multinational anti-avoidance law into Part IVA of the Income Tax Assessment Act 1936 The new law will apply to tax benefits obtained on or after 1 January 2016 It is aimed at 30 identified multinationals with Australian ...

GST on offshore services and intangible supplies
Insight 14 May 2015

GST is to be applied to the supply of services and other intangibles by non-residents to Australian consumers under legislation proposed to apply from 1 July 2017 This will include the supply of digital products and the supply of other services The liability for GST on such supplies made through an ...

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