21-30 of 49 results
Thin cap: debt deduction creation regime
In this insight, we analyse the new debt deduction creation regime and discuss its potential implications. ...
Tax benefits and desire: lessons from the Minerva Part IVA decision
The decision represents a significant win for taxpayers and provides guidance on the operation of Australia's anti-avoidance rules contained in Part IVA. ...
Clarifying aspects of the Thin Capitalisation Rules and Debt Deduction Creation Rules
In this Insight, we provide clarity to tax managers, CFOs and commercial managers seeking to evaluate the cost/benefits of undertaking a transaction, particularly with a related party. ...
Overview of state and territory Budgets 2023-24
All Australian states and territories have delivered their Budgets for 2023–24. Those Budgets' proposed changes span a spectrum from minor tax refinements to major tax reforms. ...
Allens advises on $1.5b acquisition of United Malt Group
The transaction was signed in July 2023 and completed on 15 November 2023, following receipt of various regulatory approvals in Australia, the US, the UK, Canada, France, Germany, Austria and ...
Constitutional cloud cast by High Court over state taxes affecting goods: Vanderstock and the future of federal-state taxation powers
In its recent decision of Vanderstock v Victoria, the High Court has ruled by a 4:3 majority that the Victorian electric vehicle road user charge is unconstitutional. ...
Significant expansion of the NSW duty base
The 2023 NSW budget contained a number of significant changes to stamp duty, including: the landholder duty acquisition threshold for private unit trusts has been lowered from 50% to 20% wholesale un ...
Full Federal Court dismisses Commissioner's transfer pricing appeal against Glencore
On 6 November 2020, the Full Court of the Federal Court of Australia handed down its much anticipated decision dismissing the Commissioner's appeal (save for one issue) against Glencore Investment Pty Ltd in a significant transfer pricing dispute. ...
Double-duty provisions to receive much needed guidance on what constitutes 'land development'
The Victorian SRO has released a draft revenue ruling in an effort to provide practical guidance as to what types of activities constitute 'land development'. Unfortunately, the Draft Ruling does not overcome the existing uncertainty in some common situations and arguably seeks to expand the types of activities that may be considered 'land development'. ...
Latest constitutional challenge to notional GST fails
Two recent decisions - Hornsby Shire Council v Commonwealth; and Landcom v Commissioner of Taxation - have rejected constitutional challenges to the notional goods and services tax (GST) voluntarily paid by the Commonwealth, states, local councils and statutory authorities. ...