In Taxpayer Alert TA 2017/1, the Australian Tax Office (ATO) has announced that it will be targeting arrangements which fragment integrated trading businesses, with particular emphasis on the inappropriate use of stapled...more
The House Republicans have proposed sweeping changes to the U.S. tax system, specifically that income from the export of goods, services and intangibles will not be subject to federal income tax, and that the cost of such...more
On 10 March 2016, the Senate Economics Legislation Committee published the Report on the proposed legislation which will introduce a new system for taxing attribution managed investment trusts (AMITs). Committee's Views on...more
On 22 February 2016, the Hon Scott Morrison MP, Treasurer of the Commonwealth of Australia, published a media release regarding new requirements for foreign investment applications to ensure foreign companies investing in...more
On 7 December 2015, the Federal Government released an Innovation Statement which included important tax concessions aimed at making early stage investment more attractive. The concessions are expected to commence from 1 July...more
The Tax Laws Amendment (New Tax System for Managed Investment Trusts) Bill 2015 (Bill) was tabled in Parliament on 3 December 2015, along with three supporting bills.
If passed in its present form, the Bill will...more
On October 5, 2015, the Organisation for Economic Co-operation and Development (“OECD”) published final reports outlining the “actions” to be undertaken by OECD members as part of the base erosion and profit shifting (“BEPS”)...more
The recent Full Federal Court of Australia decision in John Holland Group Pty Ltd v Commissioner of Taxation [2015] FCAFC 82 concerned whether the costs incurred by an employer to transport fly-in-fly-out (FIFO) employees,...more
On 6 November 2013, the Federal Government announced that it would introduce a 10% non-final withholding tax on the disposal of certain taxable Australian property by foreign residents. This measure aims to assist the...more
Draft Goods and Services Tax (GST) legislation has been released which seeks to level the playing field by ensuring that digital products and services provided to Australian consumers are subject to GST, whether provided by...more
On 9 April 2015, the Federal Government released exposure draft legislation to introduce a proposed new tax system for eligible managed investment trusts. The changes contained in the draft legislation largely follow...more
On 3 March 2015, legislation introducing the Exploration Development Incentive (EDI) officially passed the Australian Senate. The legislation is expected to receive Royal Assent in the coming days. The EDI has been introduced...more
In July 2013, the G20 Finance Ministers, including Australia, fully endorsed the base erosion and profit shifting (BEPS) Action Plan. As a result of the Action Plan, the Australian government encouraged a new commitment to...more
On 16 October 2014, changes to Australia's thin capitalisation and non-portfolio dividend exemption rules received Royal Assent.
The changes to the thin capitalisation rules represent a significant tightening of the...more
Following its announcement in November 2013, the Australian Government has released draft legislation to enable foreign pension funds to access concessional withholding tax rates under Australia's Managed Investment Trust...more
In the 2014 Budget, the Federal Government announced that it would introduce Exploration Development Incentive (EDI) tax credits to encourage and stimulate growth in the junior mining industry. This is a simpler approach to...more
At the time the Coalition Government (Government) was elected in September 2013, there were 96 tax and superannuation proposals announced by the previous government that had not been enacted. On 6 November 2013, the...more