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Conduit foreign income rules

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Published on 01 Oct 05 by "THE TAX SPECIALIST" JOURNAL ARTICLE

The conduit foreign income rules are the last major piece of international tax reform aimed at eliminating Australian tax on foreign sourced income flowing through Australia where the ultimate owners are non-residents.

Author profiles

Neil Billyard CTA
Neil is a Partner in International Corporate Tax at KPMG. Neil has over 22 years corporate tax experience and specialises in foreign merger and acquisition activities of Australian multi-nationals, cross-border funding, the repatriation of profits and other related structuring. He is actively involved in working with Treasury and government on a variety of international tax reform issues, including assisting with policy development and drafting of legislation. He has lectured the Master of Laws/Tax course at the University of Sydney and is a regular presenter for The Tax Institute. - Current at 01 February 2011
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Alison Young
Alison Young is a Director in KPMG’s Tax Division group and has over 10 years corporate tax experience in advising both inbound and outbound clients on a range of international tax issues. During her career, Alison has specialised in advising on the controlled foreign company and foreign investment fund rules for outbound Australian multinationals, in addition to broader funding, holding and repatriation issues for a range of clients in the property, mining, manufacturing and services industries. Alison has published a number of international tax related articles in the Taxation Institute of Australia Tax Specialist, as well as having presented previously on the RITA reforms for the Taxation Institute of Australia - Current at 31 March 2009
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