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Non-residents: What Australia is Doing to Court Them

Published on 17 Apr 2007 | Took place at Leonda by the Yarra, Hawthorn, VIC

Since 2003 the Federal Government has introduced a number of tax initiatives designed to make Australia a more attractive place for non-residents to work and invest. Some of the changes fine tune existing rules such as dividend and interest withholding tax. Others, however, fundamentally alter the way in which Australia's income tax rules apply to non-residents and their Australian investments.

This seminar focussed on Australia's non-resident tax initiatives and considered how the rules operate to benefit corporate and non-corporate taxpayers alike.

Individual sessions

Non-residents: what Australia is doing to court them

Author(s):  Michael TAYLOR-SANDS

This paper focusses on Australia's non-resident tax initiatives and considers how the rules operate to benefit corporate and non-corporate taxpayers alike. Issues covered include:

  • non-resident CGT rules: what CGT assets remain within Australia's tax net? Ongoing relevance of income / capital distinction? Reconciling domestic law with Australia's DTAs. Practical inbound structures for non-residents
  • temporary resident rules: Who qualifies? What income is concessionally taxed? In what circumstances?
  • conduit foreign income rules: How they operate? How non-resident stakeholders benefit? How resident Australian companies benefit?
  • other favourable international tax initiatives (23AJ, 23AH, CGT relief for active foreign companies, CFC & FIF changes).
Materials from this session: