111-120 of 145 results

Federal Court judgment in the Chevron transfer pricing case
Insight 10 Nov 2015

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 ...

Repeal of the Minerals Resource Rent Tax
Insight 03 Sep 2014

One year on from its election victory the Federal Government has fulfilled its commitment to repeal the Commonwealth Minerals Resource Rent Tax and related tax measures by passing a repeal Bill through the Senate yesterday The repeal is expected to take effect later this year Partner Martin Fry and ...

Diverted profits tax exposure draft Bill and explanatory memorandum released
Insight 02 Dec 2016

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 ...

Diverted Profits Tax
Insight 13 May 2016

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 ...

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 ...

Commissioner threatens to issue higher tax bills
Insight 19 Feb 2016

The Commissioner of Taxation has in a recent Australian Senate Estimates hearing expressed frustration that companies potentially subject to Australias cross-border anti-avoidance laws including the new Multinational Anti-Avoidance Law or MAAL which have documents offshore outside the reach of his ...

Resource Capital Fund IV LP: what's all the fuss about? Foreign partnerships and liability to Australian tax
Insight 23 Feb 2018

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 ...

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 ...

Recent developments in non-executive director remuneration
Insight 22 Aug 2018

Encouraging share ownership by non-executive directors through non-executive director share rights plans is set to increase following a recent ATO class ruling. ...

Government abandons some not-for-profit sector tax reforms
Insight 03 Feb 2014

The Federal Government has announced that it will proceed with only one of the backlog of announced but unlegislated reforms to the taxation of charities and other not-for-profit entities proposed by previous governments Special Counsel Glenys Hodges and Lawyer Scott Lang report on the fate of the ...

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