111-120 of 145 results
Australia's new Multinational Anti-avoidance Law moves ahead of OECD consensus
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 ...
Diverted profits tax exposure draft Bill and explanatory memorandum released
Exposure draft legislation and explanatory materials for a diverted profits tax have been released by the Federal Government Targeted at multinational groups transferring profits to offshore associates the measures will give the Commissioner of Taxation a power to issue assessments at a punitive ...
Federal Court judgment in the Chevron transfer pricing case
The Federal Courts much-anticipated judgment in emChevron Australia Holdings v Commissioner of Taxationem is the next important step in the development of Australias transfer pricing rules Partners Martin Fry and Toby Knight discuss certain implications of the decision ...
Resource Capital Fund IV LP: what's all the fuss about? Foreign partnerships and liability to Australian tax
The Federal Court has concluded that the profit made on disposal of shares in an Australian mining company by a private equity fund formed as a Cayman Islands Limited Partnership was not subject to Australian tax ...
Diverted Profits Tax
Among other measures designed to combat multinational tax avoidance contained in the 2016-17 Budget is the intended introduction of an Australian Diverted Profits Tax DPT This will broadly replicate the second limb of the existing United Kingdom DPT It will address profit shifting by Australian ...
The Asia Region Funds Passport begins to take shape
Its been a busy few months for the development of the Asia Region Funds Passport In late August the Federal Government released exposure draft legislation to accommodate the introduction of the Passport in Australia Once implemented the Passport will allow fund managers from participating economies ...
High Court decision on retention obligations provides some clarity to liquidators
The High Court has ruled that a liquidator has no obligation to retain monies on account of tax until a notice of assessment has been issued The decision will provide much needed clarity for liquidators and other statutorily deemed trustees and agents Partners Charles Armitage and Christopher ...
Comment invited on new procurement guidelines to fight black economy
Comment is being sought on new guidelines designed to enhance good tax behaviour and create an even playing field for businesses that comply with their tax obligations Partner John Greig and Lawyer Patrick Broe outline the proposed guidelines the implications for tenderers and some matters that ...
The beginning of the end of the unit trust's monopoly? CCIV legislation and ASIC guidance
Avid readers of Unravelled over the past few years cannot have failed to notice that there are moves afoot to introduce two new forms of collective investment vehicle each promising a shiny tax-neutral alternative to the unit trust and hopefully saving Australian lawyers a lot of sleepless nights ...
Long-awaited integrity package on taxation of stapled structures released
A package of tax measures that seek to address the Federal Governments perceived sustainability and tax integrity risks posed by stapled structures has been announced It also limits certain broader tax concessions currently available to foreign investors so that the potential reach of the measures ...