Australia–MNE Tax

Asia-Pacific

Former Australian head of tax watchdog Ali Noroozi joins PWC: Eryk Bagshaw / The Canberra Times→

January 23, 2019

Americas

OECD requests feedback on tax treaty dispute resolution in Australia, Ireland, Israel, Japan, Malta, Mexico, New Zealand, Portugal

November 24, 2017

The OECD on November 24 asked for taxpayer input to conduct stage 1 peer reviews of the tax dispute resolution processes in Australia, Ireland, Israel, Japan, Malta, Mexico, New Zealand, and Portugal. Taxpayers are . . .

Asia-Pacific

Australian tax office identifies tax gap from large corporates and MNEs: Nassim Khadem / The Sydney Morning Herald→

October 12, 2017

Asia-Pacific

Facebook Australia restructures, pays more tax in response to MAAL: Nassim Khadem / The Sydney Morning Herald→

May 1, 2017

Asia-Pacific

Australia’s diverted profits tax becomes law: Sydney Morning Herald→

March 29, 2017

See: Sydney Morning Herald.

Asia-Pacific

Australia consults on signing of BEPS multilateral instrument

December 21, 2016

Australia Treasury has released a discussion paper seeking comments on whether the government should sign . . .

Asia-Pacific

Japan’s tax treaties with Australia, Slovakia, and France to be altered by BEPS MLI

October 2, 2018

The Japanese government today announced that its tax treaties with Australia, Slovakia, and France have been modified because Japan and these partners have now ratified a multilateral . . .

Americas

Australia may exercise transfer pricing reconstruction power, will change approach to allocation of risk, official says

August 22, 2018

The Australian Taxation Office has not yet used its sweeping power to reconstruct transactions for transfer pricing purposes; however, that may soon change, Australian Deputy Commissioner Mark Konza said at the Tax Institute’s 2018 National Transfer . . .

Asia-Pacific

Australian tax office planning release of thin cap guidance

March 1, 2018

The Australian taxation office (ATO) has announced that it intends to soon complete five guidance projects on Australia’s thin capitalization regime. In a February 28 update, the ATO advised that it . . .

Asia-Pacific

Chevron Australia drops appeal of landmark transfer pricing decision

August 21, 2017

Chevron Australia has withdrawn an appeal to Australia’s High Court challenging a key transfer pricing decision concerning the appropriate arm’s length interest rate for a Chevron group intercompany loan. As such, the . . .

Asia-Pacific

Duff & Phelps acquires Quantera Global Asia

May 16, 2017

Duff & Phelps, a global valuation and corporate finance advisor firm, announced May 16 that it has acquired Quantera Global Asia Holding, a transfer pricing . . .

Asia-Pacific

Australia: GST proposed for low value imported goods

March 7, 2017

JP Canavan discusses a proposed law, advanced by Australian government on February 16, which would overhaul the goods and services tax (GST) regime in relation to the importation of low value goods by consumers. . .

Asia-Pacific

Australia to require nonresident retailers, platforms to register for GST: PWC→

February 22, 2017

See: PWC.

Asia-Pacific

Australian law requires local file in electronic format, no transfer pricing report: PWC→

June 14, 2016

See: PWC

Asia-Pacific

Australia to fund business tax cuts with proceeds from further multinational tax crack down: Sky News→

May 2, 2016

See: Sky News. More: Sydney Morning Herald.

Asia-Pacific

Bupa, Opal, other multinational aged care businesses avoid Australian tax via related-party loans and leases, NGO report says: Tax Justice Network→

May 3, 2018

Americas

OECD publishes updated transfer pricing profiles for 14 countries

April 9, 2018

The OECD today published transfer pricing profiles for Australia, China, Estonia, France, Georgia, Hungary, India, Israel, Liechtenstein, Norway, Poland, Portugal, Sweden, and Uruguay. The profiles

Asia-Pacific

What the Chevron decision means for Australia and transfer pricing worldwide

May 8, 2017

Nick Drizen of BDO Australia discusses the Australian Full Federal Court’s landmark decision in Chevron, providing insight into transfer pricing for intercompany loans . . .

Asia-Pacific

Australia-Germany tax treaty enters into force

December 13, 2016

A tax treaty signed between Australia and Germany entered into force on December 7, Australia’s . . .

Asia-Pacific

Google Australia restructures to avoid MAAL, will pay tax on ad revenue: Nassim Khadem / The Age→

May 2, 2016

See: The Age.

Asia-Pacific

Australia proposes to amend “significant global entity” definition: KPMG→

July 25, 2018

Asia-Pacific

Australian bid to cut corporate rate to 25 percent fails: The Ecopch Times→

June 28, 2018

Asia-Pacific

Australian Taxation Office preparing guidance on related-party interest-free loans, derivatives

December 11, 2017

The Australian Taxation Office (ATO) on December 11 announced that it intends to add two draft schedules to Practical Compliance Guideline( PCG 2017/4), which sets out the ATO’s compliance approach to cross-border related party financing arrangements and . . .

Asia-Pacific

Google Australia to fight tax bill: Tony Yoo / Business Insider→

May 1, 2017

Asia-Pacific

Australian taxation office consults on new public disclosure requirement for large businesses

August 15, 2016

The Australian Taxation Office (ATO ) has today launched a consultation on rules to implement a new law that will significantly increase public disclosures required by many large businesses operating in Australia, particularly . . .

Asia-Pacific

Australia passes tax rules on hybrid mismatches, approves MLI

August 28, 2018

Australian laws designed to curtail multinational tax avoidance through hybrid mismatch and branch mismatch arrangments and . . .

Asia-Pacific

Australia hybrid mismatch law passes parliament, awaits Royal Assent: EY→

August 18, 2018

Asia-Pacific

Facebook Australia settles with tax authority, pays AUD 31m (USD 23.2 m) more for tax years 2009–2015: Chris Duckett / ZDNet→

May 3, 2018

Asia-Pacific

Australian bill excludes passive investment companies from lower tax rate

October 18, 2017

The Australian government today introduced legislation clarifying that passive investment companies will not qualify for the lower 27.6 percent company tax rate. Under the bill, a company will not qualify for the lower . . .

Americas

US to exchange country-by-country reports with Australia, Estonia

August 3, 2017

The US IRS today announced that it has entered into separate agreements with Australia and Estonia to exchange country-by-country reports . . .

Asia-Pacific

Australia publishes tax bills of large domestic and foreign businesses

December 13, 2016

The Australian government on December 9 released its latest corporate tax transparency report, making public the 2014–15 tax details of 1,904 large . . .

Asia-Pacific

Australia proposes new debt-equity tax rules

October 10, 2016

The Australian government has released draft legislation for public comment that would amend the country’s debt-equity tax . . .

Asia-Pacific

Australian guidance details procedure when transfer pricing adjustments affect customs values

April 15, 2016

The Australian government has released details on the how the tax office (ATO) will respond to taxpayer requests for help determining customs duty values following a . . .

Asia-Pacific

Singapore describes how the MLI affects 14 of its bilateral tax treaties

April 5, 2019

The Inland Revenue Authority of Singapore (IRAs) has provided information about how . . .

Asia-Pacific

BHP Billiton to appeal High Court in tax dispute involving Singapore marketing hub: Tom McIlroy / Financial Review→

March 13, 2019

Asia-Pacific

Australia, France, Japan, Slovak Republic ratifiy BEPS MLI

September 27, 2018

Australia, France, Japan, and the Slovak Republic have ratified a multilateral tax treaty designed to swiftly add to their existing tax treaties . . .

Asia-Pacific

Australian tax authority challenging Exxon subsidiary’s intercompany loan interest deductions: Peter Ker / Financial Review→

April 27, 2018

Asia-Pacific

Australia: tax guidance on cross-border related party financing released

May 16, 2017

The Australian Taxation Office on May 16 issued draft guidelines on cross-border related party financing arrangements. In the . . .

Asia-Pacific

Transfer pricing specialist Joel Phillips joins BDO Australia

June 7, 2018

Transfer pricing specialist, Joel Phillips, has joined BDO as a partner in its Sydney office, the . . .

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Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

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