The Australian Taxation Office (ATO) intends to enter into discussions with about 80 multinational enterprises expected to be affected by an antiavoidance law introduced into Parliament . . .
Australia will introduce transfer pricing documentation requirements for multinationals, including country-by-country reporting, consistent with guidance developed under the OECD/G20 base erosion and profit shifting (BEPS) plan, the government announced in 2015 budget papers released May 12. The government also released exposure drafts of legislation for a new targeted antiavoidance rule that is aimed at . . .
The Australian Taxation Office on March 19 ruled that a nonresident entity that invests indirectly in an Australian resident company through one or more interposed entities where the final leg in the chain is a debt interest . . .
Australia, on July 11, announced a consultation on proposed legislation designed to ensure that foreign pension funds
. . .
The Australian government on May 11 announced plans to beef up antiavoidance rules to tax multinational profits diverted from Australia and to propose laws to ensure that offshore suppliers of digital products and services pay goods and services tax (GST). The proposals will be unveiled in the government’s . . .
The Australian Taxation Office (ATO) on February 26 released guidance on procedures that must be followed before ATO personnel can advance the view that a transaction must be reconstructed for transfer pricing purposes using one of the exceptions. . .
Australia’s Treasury has invited stakeholders to comment on Australia’s tax treaty negotiation program, including which countries Australia should seek to negotiate with and what outcomes are desirable when negotiating tax treaties with other countries. Release
Australia’s Federal Court has handed the Australian Taxation Office (ATO) an important victory, concluding that USD 2.5 billion of loans between Chevron’s Australian-resident company and its Delaware subsidiary made between 2004-2008 were not arm’s length and thus generated excessive interest . . .
Australia has, for the first time, transmitted information to the US government on US-owned financial accounts under an arrangement designed to combat offshore tax . . .
Australia’s new Prime Minister Malcolm Turnbull announced his new ministry on Sunday, including the appointment of Scott Morrison as Treasurer. Morrison replaces Joe Hockey, who is . . .
Representatives of nine multinational pharmaceutical companies will defend their companies’ tax practices before the Australian Senate’s Economics References Committee on July 1 as a part of the committee’s ongoing inquiry into tax avoidance and aggressive tax . . .
The Australian Taxation Office (ATO) on November 22 released guidance on a proposed antiavoidance law being considered by Parliament that is designed to combat the use of artificial or contrived arrangements by multinationals to avoid attribution of profits to Australian permanent establishments. Also, Australia’s Board of Taxation . . .
Australia’s Treasurer Joe Hockey on September 17 announced that Australia intends to commence tax treaty negotiations . . .
The OECD’s Pascal Saint-Amans sought to allay Australian lawmakers’ fears that the OECD will fail in its mission to curb tax avoidance through its base erosion and profit (BEPS) plan during an Australian senate hearing, as the senators weighed whether they should support immediate unilateral tax measures to protect . . .
The Australian government on May 27 introduced into Parliament legislation enhancing the Australian Investment Manager Regime, providing some widely-held foreign funds and funds that use an Australian fund manager with a exemption from tax on Australian source income and gain, writes Deloitte in a May 28 tax alert. See, Deloitte.
The Australian Tax Office’s (ATO) tax compliance efforts targeting international business and public groups focuses on specific tax risks, such as losses and profit shifting, and on specific events in the business life cycle, such as private equity investments and mergers and acquisitions, the agency said in a March 2. . .
Australia’s Tax Laws Amendment (Combating Multinational Tax Avoidance) Bill 2015 received Royal Assent on December 11, giving effect to measures announced . . .
The Australian Taxation Office (ATO) on September 8 published the results of a consultation on rules implementing a new law that requires the ATO to publicly disclose tax information of companies that have income of $100 million or more and . . .
The Australian government, on July 14, published the terms of reference for a Board of Taxation consultation on implementing anti-hybrid rules developed. . .
Australia’s Tax and Superannuation Laws Amendment (2014 Measures No. 4) Bill 2014 received Royal Assent on October 16. The law includes provisions tightening Australia’s thin capitalization rules and reforming the tax exemption for foreign non-portfolio dividends paid to Australian corporations. See, Parliament of Australia.
The Australian Taxation Office on November 10 published a general overview if Australia’s advance pricing arrangement (APA) program. See: Australian Taxation Office.
Australia’s Treasurer on October 7 released an exposure draft of legislation that would extend the GST to digital products . . .
The Australian government on September 16 moved forward with plans to address multinational tax avoidance, introducing a bill in the House of Representatives that targets large companies that avoid the permanent establishment rules. The bill also proposes new transfer pricing documentation and country-by-country . . .
The Australian Taxation Office (ATO) on July 8 announced that it is developing a practical guide to help taxpayers self-assess their transfer-pricing activity in respect to related party offshore marketing hubs. The hubs provide marketing and sales functions for goods . . .
Australian Greens Leader Christine Milne has announced that her party will introduce on October 28 the Corporations Amendment (Publish What You Pay) Bill 2014, which will require reporting of payments made by Australian-based extractive companies to foreign governments on a country-by-country and . . .
Bitcoin is not foreign currency but is an asset subject to capital gains tax, so transacting in bitcoin is similar to bartering, the Australian tax office (ATO) concluded in a package of draft guidance released on August 20.
The ATO said that businesses receiving bitcoin as payment for goods or . . .
Australia’s Treasury on April 28 released an exposure draft of tax legislation designed to plug loopholes in the consolidation regime. According to a release accompanying . . .
New Zealand expects in 2015 to negotiate tax treaties or protocols with Korea, Australia, Norway, Slovak Republic, China . . .
Treasurer Joe Hockey in a Sept. 4 release said that he has asked the Commissioner of Taxation to examine whether location specific profits are being generated in Australia on account of the high prices multinationals charge to consumers and, if so, whether multinationals are appropriately allocating these profits to Australian operations under the transfer pricing rules.
“Australian consumers often pay much higher prices compared to United States . . .
Switzerland’s Federal Council on April 29 initiated a consultation on a federal decree which would implement automatic exchange of information in tax matters with Australia. The consultation follows up on a joint declaration . . .
The Australian Taxation Office (ATO) on November 12 released a final taxation ruling which sets out the circumstances under which a taxpayer must disregard actual transactions with a related party and instead use hypothetical arm’s length conditions to determine income and withholding tax. The ruling interprets section 815-130 of the Income Tax Assessment . . .
“Powerful vested interests will be very upset about this,” Australia’s Treasurer Joe Hockey said, according to a September 7 article by Adam Creighton of the Business Spectator. See: Business Spectator. Related: MNE Tax.
Tax officials from 21 Asia Pacific countries and organizations attended an OECD regional network meeting on base erosion and profit shifting (BEPS) designed to give more nations a voice in the development of OECD/G20 base erosion profiting shifting (BEPS) plan output. The meeting, held February 12–13 in Seoul, also . . .
Pharmaceutical companies could be the next target of an Australian Senate inquiry into tax avoidance, according to a May 22 report by the Brisbane Times. See, Brisbane Times
OECD, G-20, and other tax administrator are working together on a project to map of the global operation of selected MNEs engaged in the digital economy, Australian Second Commissioner Neil Olesen said November 28. “In today’s world, multinationals . . .
Ashish Dave has joined Quantera Global as a Director in the firm’s Sydney, Australia, office. Release
The Australian goverment on July 7 launched a consultation on proposed legislation that would impose a 10 percent withholding tax on the disposal of Australian property by foreign residents. The tax is designed to . . .
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