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Outbound investment by private clients – What structure to use paper?

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Published on 13 Apr 08 by NATIONAL EVENTS, TAXATION INSTITUTE OF AUSTRALIA

This paper covers:

  • what foreign entity to use for the investment, ie foreign company, branch, partnership etc
  • profit and cash repatriation issues and opportunities
  • funding the investment
  • impact of tax treaties, including allocation of taxing rights and withholding taxes etc
  • treatment of related party transactions
  • issues and opportunities arising from the interplay between Australian tax law and the tax law of the local jurisdiction
  • examples of specific issues affecting investments in certain jurisdictions.

Author profiles

Mathew Chamberlain CTA
Mathew Chamberlain, CTA, is a partner at EY and leads the Perth International Tax Services team. A legal practitioner admitted in WA and NSW, he has more than 32 years’ experience in international tax, focusing on the large multinational and corporate environments across Australia, the US, Europe, Asia-Pacific and Africa. Mathew specialises in international tax reform, foreign investment into Australia and outbound investment from Australia. A long-time member of The Tax Institute, Mathew has presented at numerous national and state conventions on international tax issues and has also lectured on tax law at UWA and Curtin. Mathew has also led and participated in a number of government and ATO initiatives, working groups etc. on international tax law and policy issues affecting Australian inbound and outbound investment, including most recently submissions to and liaisons with government on corporate tax residency, the new thin capitalisation and debt deduction creation rules and the treatment of taxpayers in the oil and gas services and shipping industries. - Current at 01 November 2024
Click here to expand/collapse more articles by Mathew CHAMBERLAIN.
Anna KLIMCZAK
Anna is a Senior Consultant with Ernst & Young.

 

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