Jock McCormack

Jock McCormack

DLA Piper

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Latest Publications


Australian Tax Update - October 2015

The Chevron decision provides critically important guidance on both the 'old' (Division 13) and 'new' (Subdivision 815-A) transfer pricing laws in Australia. While not dealing specifically with Subdivisions 815-B to D, the...more

10/30/2015 - Chevron Corporate Financing Corporate Taxes Cross-Border Cross-Border Transactions Debt Financing Double Taxation Foreign Subsidiaries Income Tax Treaty International Tax Issues Subsidiaries Tax Treaty Transfer Pricing

Australian Tax Alert: Australia Pursues Multinational Tax Avoidance

In the context of the imminent release of the OECD report to G20 finance ministers (in October 2015) dealing with its final recommendations on the Base Erosion Profit Shifting (BEPS) Action Plan, Australia has introduced...more

9/24/2015 - Audits Australia Australian Tax Authority BEPS Corporate Taxes G20 Multinationals OECD Proposed Legislation Tax Avoidance

Australian Taxation Office issues new Practice Statement on Advance Pricing Arrangements

The tax and in particular the transfer pricing arrangements of multinationals is currently under the spotlight both internationally, through the OECD/G20 BEPS project, and domestically in Australia, by way of the Senate...more

8/3/2015 - Australia BEPS G20 OECD Transfer Pricing UK

Australian Tax Alert: Investment Manager Regime (IMR) – Bill To Implement Element 3 Is Now Law

Tax and Superannuation Laws Amendment (2015 Measures No. 1) Bill 2015 (the Bill), containing the third element of the IMR, has been passed by the Australian Parliament and received Royal Assent on Thursday 25 June 2015. This...more

7/1/2015 - Australia Corporate Taxes Foreign Investment Investment Management Proposed Amendments

Australian Tax Alert - Investment Manager Regime (IMR) – Draft Legislation To Implement Element 3 Finally Released

The exposure draft (ED) legislation removes tax impediments for foreign investors investing into Australia in order to attract foreign investment and promote the use of Australian fund managers. OVERVIEW - The...more

3/27/2015 - Australia Corporate Taxes Foreign Investment Fund Managers Investment Management Tax Exemptions

Recent Developments - Australian Transfer Pricing (TP) Rules: Time To Step Up

With the Australian Taxation Office's (ATO) escalating focus on international profit shifting, it is essential for multinational taxpayers (MNEs) to properly understand the new Australian Transfer Pricing (TP) rules, assess...more

3/12/2015 - Australia Corporate Taxes Cross-Border Transactions Multinationals OECD Transfer Pricing

Sports, Media and Entertainment Intelligence - March 2015 (Global)

BROADCASTING - Italy: Back to the future - connected TVs need "connected regulations" - The Italian Communications Authority recently adopted resolutions concerning changes in the broadcasting landscape....more

3/6/2015 - Australia Copyright EU FIFA Germany Internet of Things Italy Media Music Industry Sports Television Programming

Australia: What is and is not a “royalty” for withholding tax purposes? Latest key court decision

By Jock McCormack, James Newnham, Matthew Cridland and Eddie Ahn Introduction The taxpayer, Seven Network Limited, has won a recent decision (22 December 2014) in the Australian Federal Court, Seven Network Limited v Federal...more

2/2/2015 - Australia Broadcasting Entertainment Industry Royalties Sports Withholding Tax

Important royalty withholding tax decision

The taxpayer, Seven Network Limited, has won a recent decision (22 December 2014) in the Australian Federal Court, Seven Network Limited v Federal Commissioner of Taxation (2014) FCA1411, which is significant to all...more

1/29/2015 - Australia Broadcasting Entertainment Industry Royalties Sports Withholding Tax

Doing Business in Australia

With strong economic fundamentals, a positive outlook, proximity and strong trade links with some of the world’s most dynamic economies, Australia offers a wealth of opportunities for global investors and multinational...more


International Tax News - September 2014

BASE EROSION PROFIT SHIFTING PROJECT RECOMMENDATIONS TO COMBAT TAX AVOIDANCE BY MULTINATIONALS - At the request of the G20 Leaders, the Organisation for Economic Co-Operation and Development (OECD) has been considering...more

9/25/2014 - BEPS Corporate Taxes G20 Income Taxes International Tax Issues Multinationals Tax Evasion

Base erosion profit shifting project recommendations to combat tax avoidance by multinationals

At the request of the G20 Leaders, the Organisation for Economic Co-Operation and Development (OECD) has been considering 15 key elements to be addressed by 2015 for a co-ordinated international approach to combat tax...more

9/18/2014 - BEPS Corporate Taxes Erosion G20 Multinationals OECD Tax Evasion

International Tax News - July 2014

BITCOIN FORGES AHEAD: 3 QUICK LOOKS - Bitcoin is a decentralized peer-to-peer payment system that exists virtually and is unlimited by the constraints of countries, government or time. In an age when business leaps...more

7/28/2014 - Bitcoin Business Taxes Carbon Taxes Corporate Taxes International Tax Issues Virtual Currency

Australian Tax Update: Repeal Of The Carbon Tax - Easy Come Easy Go?

The Federal Government has fulfilled its election promise when the Senate passed the carbon tax repeal legislation on 17 July 2014. The Government achieved the repeal of the carbon tax after 2 weeks of negotiations with the...more

7/17/2014 - Australia Carbon Taxes

Australian Tax Update: Australian Budget 2014-2015

2014-2015 Australian Federal Budget - Government takes its first steps of tax reform in preparation for a broader comprehensive review of the Australian taxation system. INTRODUCTION - The Australian Coalition...more

5/14/2014 - Australia Federal Budget Fuel Tax R&D Tax Credits

Australia’s new transfer pricing laws overlap the thin cap rules: new challenges for taxpayers

The overlap of Australia's new transfer pricing laws with the thin capitalization rules is causing challenges and likely duplication of analysis for taxpayers - particularly for the arm's length amount-of-debt...more

2/28/2014 - Australia OECD Thin Capitalization Transfer Pricing

International Tax News - November 2013

US-SWISS VOLUNTARY DISCLOSURE PROGRAM: DEADLINES ARE LOOMING – SWISS BANKS NEED NOT PANIC, BUT MUST ACT SWIFTLY AND THOUGHTFULLY - The recently announced voluntary bank disclosure program between Switzerland and the...more

11/25/2013 - Australia Banks EU Foreign Bank Accounts Income Taxes IRS Tax Evasion Tax Treaty Voluntary Disclosure

Government Update On Previously Announced Tax Measures (Australia)

Over the past 12 years, 96 tax related measures have been announced by former governments which have not been legislated. These outstanding tax measures have created uncertainty for taxpayers, of varying degrees. Where a tax...more

11/8/2013 - Australia International Tax Issues Tax Rates

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