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Trans Tasman Taxation - Investing in our ANZAC neighbour
Published on 08 Apr 2003 | Took place at Le Meridien at Rialto, Melbourne, VIC
Trans Tasman taxation issues are in the spotlight following the recent announcement by the Treasurer that Australia and New Zealand will extend their imputation systems to include companies resident in the other country.
With the focus on reform of the 'triangular tax problem', it is timely to examine the range of complex taxation issues associated with investing in our ANZAC neighbour.
In this seminar, Australian/NZ tax experts help you understand the complexities, alternatives, risks and critical opportunities associated with Trans Tasman investment and trade, including:
- strategic funding alternatives
- questions of dual residency, migration and branches
- operation of the respective anti-avoidance regimes
- implications of the triangular tax reform proposals.
Get a 20% discount when you buy all the items from this event.
Individual sessions
The Funding Smorgasbord
Author(s):
Craig SAUNDERS,
Joanne McCRAE
This seminar paper covers the following topics:
- funding structures - risks and rewards
- share capital - redeemable vs ordinary
- FC 1 & FC 2
- convertible notes
- forward purchase agreements
- conduit regime - timing/unwind/compliance
- other structures, eg. limited partnerships.
Materials from this session:
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Triangular Tax Reform
Author(s):
David STEVENS
This seminar paper covers the following issues:
- the proposals
- implications and opportunities
- interaction with Review of International Tax Arrangements.
Materials from this session:
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Dual Residency Issues including Migration and Branches
Author(s):
Tim WALTON,
Anthony KLEIN
This seminar paper covers the following topics:
- when does a company become a dual resident
- treaty override - under whose view NZ or Australia
- impact of dual residency
-- branches - profit recognition - NZ or Australian basis
-- repatriation profits - dividends
-- imputation credit accounts
- consolidation - any opportunities
- migration - risks and rewards.
Materials from this session:
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Avoidance - BG1 vs Part IVA
Author(s):
Andrew BABBAGE
This seminar paper covers the following topics:
- similarities between the anti-avoidance measures
- important issues of distinction
- relevant considerations for Australian investors.
Materials from this session:
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