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2014 Financial Services Taxation Conference

Published on 19 Feb 2014 | Took place at InterContinental Sanctuary Cove Resort, Gold Coast, NSW

The global tax landscape is facing significant change as international institutions including G20 and the OECD consider the impact of base erosion and profit shifting (BEPS). This change is expected to find its way into the domestic legislation of Australia and that of our trading partners. This event considered these developments.

This event also covered numerous tax issues that will impact our industry, from the new transfer pricing rules, to Part IVA, trust issues and the ever-popular cases update to mention a few.

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Individual sessions

BEPS: OECD perspective

Author(s):  Richard J VANN

This paper covers:

  • background and overview
  • what is the BEPS problem?
  • what are the likely outcomes of the action plan?
Materials from this session:

Policy and tax reform

Author(s):  John Freebairn

This paper covers:

  • introduction
  • arguments for tax reform
  • income taxation
  • general expenditure taxes
  • special purpose indirect taxes
  • transaction taxes
  • taxation of assets and wealth
  • simplification
  • policy process.
Materials from this session:

Current issues relating to trusts Division 6C and MITs

Author(s):  Karen PAYNE

This paper covers:

  • taxing the trustee of a transparent trust – the current rules:
    • how and when does the Tax Act assess trustees for tax liabilities of the trust?
    • collecting tax from the trustee
    • absolute entitlement- taxing the trustee or the beneficiary
    • assessing trustees where there has been a resettlement of a trust
    • which trustee to collect from where there is a change of trustee?
    • collecting taxes from a trustee in liquidation
    • withholding taxes.
Materials from this session:

The attribution of profits to permanent establishments

Author(s):  Ian FULLERTON

This paper covers:

  • principles for attributing profits to PEs (excluding Subdivisions 815-B and 815-C)
  • practical issues in PE profit attribution
  • effect of Subdivisions 815-B and 815-C of ITAA 1997
  • effect of adopting the AOA
  • adoption of the AOA by other countries.
Materials from this session:

Transfer pricing aspects of insurance & reinsurance

Author(s):  Geoffrey GILL,  Cameron Smith

This paper covers:

  • reinsurance arrangements
  • investment management activities
  • intra-group services
  • attribution of profits to insurance PEs
  • transfer pricing developments impacting insurance & reinsurance entities.
Materials from this session:

Tax deferred distributions

Author(s):  Antoinette ELIAS,  Brian Lane

This paper covers:

  • another item for legislative change?
  • the issue – ATO ID 2011/58
  • practical application of ATOID revenue treatment views
  • treasury and the Government’s views
  • technical analysis.
Materials from this session:

Tax issues in restructures, acquisitions and dealing with distressed debt

Author(s):  Ian KELLOCK

This paper covers:

  • does the forgiveness of debt result in the derivation of ordinary income by the debtor?
  • commercial debt forgiveness rules
  • limited recourse debt
  • forbearance transactions - issues for the creditor
  • conversion of debt to equity
  • transactions involving the assignment of debt.
Materials from this session:

Financial transaction taxes - Current state of play and potential impacts

Author(s):  Gavin MARJORAM

This paper covers:

  • the current ‘state of play’
  • the basic chargeability
  • the scope of taxation
  • payment/collection of tax
  • anti-avoidance rules
  • application of the FTT to common transactions.
Materials from this session:

BEPS: Treaty aspects

Author(s):  Claudio Cimetta

This paper covers:

  • overview of tax treaties
  • BEPS and treaties
  • hybrid mismatches
  • PE status
  • transfer pricing.
Materials from this session:

Income tax and The Personal Property Securities Act 2009 (C’wlth)

Author(s):  David WOOD

This paper covers:

  • section 260-5
  • securities prior to the PPSA
  • quasi-securities
  • the PPSA: An overview
  • new concepts
  • security agreement 
  • PPS leases
  • PMSI whimsy (purchase money security interest)
  • security interests and section 260-5 notices
  • relevance of security interests generally to income tax
  • section 254 and the PPSA
  • taxation determination TD 2012/D7
  • is a receiver an agent of the debtor?
  • obligation to retain “tax which is or will become due”.
Materials from this session:

Review of the debt/equity tax rules

Author(s):  Teresa DYSON

This paper covers:

  • policy design of Division 974
  • operation of the debt/equity rules
  • the application of section 974-80.
Materials from this session:

FATCA - What is the state of play?

Author(s):  William BROWN

This presentation covers:

  • overview
  • IGAs
  • regulations
  • withholding
  • reporting
  • challenges.
Materials from this session:

Liabilities – A changing world post TOFA

Author(s):  Euan CAMPBELL,  Andrew Hirst

This paper covers:

  • pre-TOFA treatment of liabilities
  • TOFA – bringing liabilities more comprehensively into the tax system
  • TOFA liabilities – specific examples
  • TOFA/consolidation interactions
  • future direction.
Materials from this session:

The new transfer pricing rules in the context of financial services

Author(s):  Kristen DEARDS,  Sarah Stevens

This paper covers:

  • choice of transfer pricing method
  • re-characterisation of financial transactions
  • use of the OECD commentary
  • interaction with thin capitalisation
  • new documentation requirements
  • OECD developments on transfer pricing documentation and intangibles.
Materials from this session:

Taxation of life insurance companies – Reflections on the 2000 reforms

Author(s):  Patrick Grob,  Jeremy Hirchhorn

This paper covers:

  • background to the reform of life insurance taxation
  • observations
  • effect of Division 320 on revenue projections/collections
  • the 2004 reforms.
Materials from this session:

Recent cases

Author(s):  Joanne DUNNE,  Juliette Mason,  James Patto

This paper covers Federal Court 2013 tax cases.

Materials from this session:

Offshore banking units

Author(s):  Tony FROST,  Ultan MacDonald,  Craig Marston

This paper covers:

  • offshore banking in Australia (including legislative responses thereto)
  • overview of the OBU regime
  • how are OBUs currently being used? (Does OBU really stand for only barely usable?)
  • can we compete against Singapore and other financial centres?
  • what reforms will make OBUs more useful and competitive to both Australian and foreign owned institutions?
Materials from this session: