The effect of McDermott on our international tax rules presentation

Published on 12 Oct 07 by VICTORIAN DIVISION, THE TAX INSTITUTE

With the Court in McDermott finding that ‘you don’t have to be here to be here’ for PE purposes, this presentation examines the PE related issues:

• insights into consequences for internationals PE tax planning including Australia withholding tax implications for Singapore entities and what does the case mean for hiring arrangements and cross border leases
• implications for PE royalty arrangements governed by other treaties
• comparison of the Singapore treaty with other treaties and whether the existence of a treaty really matters
• why the ATO does not want you to have a PE and what action do we expect from the ATO?

Author profile

Peter Van Den Broek CTA

Very interesting perspective and format of session Tough topic • understands well I appreciate the time peter would have put into his presentation and useful paper Stand out speaker of the day • very practical and candid - Current at 01 March 2011

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