Mark Friezer runs through the options for repatriating funds from an Australian subsidiary of a foreign parent company.

Clients have received ATO letters asserting that they are Australian tax residents if they fail to demonstrate otherwise.

Recent developments for tax agents, who now need to comply with the Tax Agent Services (Code of Professional Conduct).

In summary, Treasury states that the recharacterisation results in "taxation distortions" and that the federal government "is considering measures which remove the tax advantages of stapled arrangements".

Changes introduced by this double tax treaty will impact current structures and future deals involving German entities.

The recent judgment by the Australian High Court in the PepsiCo case has sparked significant interest in international tax circles. At the core of the debate: can a fee for the purchase of goods include...

The Court agreed with the Commissioner of Taxation, with the result that the royalties were subject to withholding tax.

The Australian Taxation Office (ATO) issued a new draft taxation ruling (TR 2024/D1) on 17 January 2024 in relation to the character of receipts...

New case highlights the requirements of becoming a foreign resident for tax purposes in Australia.

Australia's shipping industry received a much needed life-line when the report 'Rebuilding Australia's Coastal Shipping Industry' was tabled into Federal Parliament on 20 October 2008.

In a speech by Wayne Swan (the then Opposition Treasurer) on 3 April 2007 and in Kevin Rudd’s Address in Reply to the Budget in May 2007, Labor committed itself to halve the current 30% withholding tax on distributions from Australian managed investment trusts to foreign investors to 15%.

Investing directly offshore rather than indirectly through Australian Funds will provide a more favourable GST outcome. The decision by the Federal Court in AXA Asia Pacific Holdings Limited v Commissioner limits the availability of input tax credits on acquisitions related to interests held in Australian funds which invest wholly overseas.

the Assistant Treasurer released draft legislation to change the application of GST on domestic transport. Announced in the last Federal Budget, they are aimed at reducing the GST compliance burden for transport providers. The Government has provided one week for public submissions to be made. being 5th March. This leaves interested parties with minimal time to absorb the proposed changes and determine whether they provide a solution for the current complicated GST outcomes that arise for r

East Timor began arbitration proceedings regarding the distribution of revenue derived from the Greater Sunrise field.

The proposed FAF rules were introduced as part of a wider package of reforms to Australia's foreign-source income attribution rules that were announced in May 2009 Federal Budget.

In February 2011 the Assistant Treasurer released a further exposure draft of the foreign accumulation fund (FAF) rules. These rules are intended as specific narrowly defined anti-avoidance rules that will replace the foreign investment fund (FIF) regime.

This 2014 decision considered the Australian/US double tax treaty, and principles for valuation of business components.

Update on key developments in taxation law for accountants and participants in the tax advice industry up to mid-May.

A skilled international tax expert would help businesses reduce risks and develop effective tax planning strategies.

The Australian Taxation Office has released its Decision Impact Statement following the High Court's landmark Bendel judgment on unpaid present entitlements and Division 7A. While some taxpayers who maintained passive arrangements may find relief, significant questions remain about the application of anti-avoidance provisions and the Commissioner's discretionary powers. The statement signals important changes to longstanding ATO guidance and raises critical considerations for trust and corporate beneficiary