31-40 of 146 results
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. ...
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. ...
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 ...
Thin cap: debt deduction creation regime
In this insight, we analyse the new debt deduction creation regime and discuss its potential implications. ...
Has the ATO tolled the bell for demerger and acquisition scheme structures?
The Deputy Commissioner of Taxation has formally refused a request from AMA Group Limited for demerger relief in connection with a demerger and acquisition transaction involving private equity firm Blackstone casting doubt on the availability of capital gains and income-tax relief for transactions ...
Landholder duty risks associated with international transactions surface in Crocodile Gold case
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 ...
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. ...
Closing valuation gaps, unlocking value
The current Australian M&A landscape continues to be marked by a tough valuation environment, with bid-ask spreads, interest rate uncertainty and an uncertain macroeconomic backdrop making completion of transactions difficult. ...
Federal Budget 2023–24: five key takeaways for general counsel
Here is our take on the essential issues for General Counsel arising from the Federal Budget (Budget) 2023-24. ...
Treasury proposes new anti-avoidance measure for intragroup payments connected with intangibles in low-tax jurisdictions
The Federal Government is proposing to deny the ability of significant global entities to deduct payments relating to intangible assets connected with low corporate tax jurisdictions. ...