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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 ...
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 ...
Recent developments in non-executive director remuneration
Encouraging share ownership by non-executive directors through non-executive director share rights plans is set to increase following a recent ATO class ruling. ...
Are CCIVS the beginning of the end for the Unit Trust's monopoly?
The Federal Government has proposed to introduce two new forms of collective investment vehicle – each a shiny, tax-neutral alternative to the unit trust. ...
Developers should tread carefully following dramatic stamp duty changes in Victoria
The Victorian Government has proposed amendments to the Duties Act which could have a dramatic impact on the stamp duty outcomes for development projects particularly for residential developments and other fee for service arrangements for real estate in Victoria. ...
Changes to the rules governing foreign investment in Australian agriculture
The Australian Government has announced that from 1 March 2015 acquisitions of agricultural land worth more than A15 million and any additional acquisitions over and above that amount will require government approval It will also establish a foreign ownership register of agricultural land ...
Can listed companies continue to claim tax deductions for contributions to employee share trusts?
A recent draft tax ruling may make it more difficult for employers to claim tax deductions for contributions made to employee remuneration trusts However the ruling is expected to have limited practical application to listed companies making non-refundable contributions to traditional employee share ...
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 ...
Long-awaited reform to company loss rules
The company loss recoupment rules have been amended to give effect to long-awaited reforms to the continuity of ownership tests This will assist companies that have multiple classes of shares with unequal rights to dividends capital distributions and voting power Partner Martin Fry and Associate Jay ...
Queensland foreign stamp duty surcharge - relief guidelines issued
New relief guidelines have been issued on Queensland's foreign stamp duty surcharge ...