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Red Series: International Tax Masterclass
Published on 27 Feb 1998 | Took place at Grand Hyatt, Melbourne, VIC
This seminar looks at the latest developments in international tax issues, with particular empasis on the operation of Ausralia's double tax treaties and recent changes to the taxation of foreign source income and international transactions.
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Individual sessions
Transferor Trusts
Author(s):
Richard SHADDICK
Topics covered include: are you, or are you not, a transeror?; cold comforts; other comforts.
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Permanent Establishments: Common & Topical Issues
Author(s):
Tim COX
This seminar paper covers issues regarding permanent establishments including issues on agencies and e-commerce.
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Treaty Shopping & Part IVA
Author(s):
The Hon. Justice Ian GZELL
- can you afford to go treaty shopping?
- does Part IVA apply?
- some observations from Lamesa
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Application of business profits articles to CGT
Author(s):
Jason CHANG
Topics covered include: meanings of 'profit' and 'enterprise'; interaction with other articles; tax planning considerations.
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Impact of 1997 legislative changes
Author(s):
Zorach DISKIN
Topics covered include: whatever happened to USSR, Czechoslavakia, and Yugoslavia?; living with foreign income and changes in the foreign income list.
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Royalty WHT Issues and DTAS
Author(s):
Chris BIRCHALL
This seminar paper discusses the Australian approach to Royalty WHT in comparison to the OECD model tax treaty.
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Cross border leasing
Author(s):
Charles ARMITAGE
Topics covered include: the current state of play; when is a royalty not a royalty?; double dipping without tripping.
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