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Corporate Tax Conference

Published on 14 Nov 2013 | Took place at Permelia Hilton, Perth, WA

    This event covered the following topics:
  • statutory interpretation
  • current financing issues
  • consolidations – where are we at?
  • international tax update – with a focus on BEPS
  • tax and ethics
  • a series of practical presentations on managing tax disputes with the ATO.

Get a 20% discount when you buy all the items from this event.

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Individual sessions

The financing challenge in Western Australia

Author(s):  Michael BONA,  Andrew Tran,  Rob YOUNG,  Matthew Budge

This paper considers some of the current technical tax issues associated with common financing challenges in WA including:

  • debt equity
  • hybrids
  • thin cap
  • 128F
  • Div 250 and infrastructure.
Materials from this session:

Keynote speech: Statuatory interpretation in a tax context

Author(s):  John Fickling

The task of interpreting the Tax Acts is not getting any easier. Many measures, particularly in the corporate tax space, are obscure and the underlying purpose is not always obvious. In this context, understanding the rules of statutory interpretation is vital. This presentation reflects on how the process of statutory interpretation has been approached in a number of recent cases and also touch on some older cases.

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Tax consolidation - Where are we at?

Author(s):  Narelle MCBRIDE

This paper covers:

  • issues now faced by corporates under the new prospective rules for tax cost setting
  • changes to the regime that were accepted by the previous Government and in the 2013/14 budget
  • future anticipated changes to the regime
  • other issues subject to further consultation.
Materials from this session:

Tax and ethics

Author(s):  David DRUMMOND,  Eliza GARRETT,  James GORDON

Having regard to the current push for transparency and likely developments over the next 2-3 years, this paper explores how Corporates and Tax Advisers should:

  • define ethics in relation to Tax
  • manage the consideration of tax risk, both financial and reputational
  • differentiate between management of Strategic and Operational Tax Risks
  • revise the application of the traditional three lines of defence to Tax Risk
  • address legacy and current tax disputes and issues with the ATO
  • respond to media enquiry into their tax affairs in this emerging environment.
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How to deal with the ATO/Managing tax disputes

Author(s):  Richard McBRIDE

The ATO uses Annual Compliance Arrangements (ACA) as the centrepiece of their efforts to build enhanced positive relationships and compliance outcomes with large business. In 2012, Alcoa signed up to an ACA covering Income Tax, FBT, GST and Excise. They were the first company to sign up for all four taxes. Richard shares his journey to date together with the outcomes so far.

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Tips for managing tax disputes

Author(s):  Jonathon LEEK

This presentation covers the following on how to deal with the ATO when managing tax disputes:

  • rights and obligations
  • what should you keep copies of?
  • what should you / should you not do?
  • protocols
  • practical management.
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Alternative dispute resolutions

Author(s):  Niv TADMORE

In recent times, the ATO has made fundamental changes to its approach to Alternative Dispute Resolutions. The increasing significance of ADR, particularly litigation, has strategic consequences for the management of early stages of disputes with the ATO.

This presentation covers:

  • recent trends in the use of ADR by the ATO
  • PSLA 2013/3 - Alternative Dispute Resolution in ATO disputes
  • strategic considerations arising from early ADR engagement with the ATO.
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International tax: The BEPs movement

Author(s):  Peter COLLINS,  Lynn KOH,  John RATNA,  Ikhwan ISLAM,  Tobias DOWIDAT

This paper covers:

  • debt dumping budget measures (including demise of 25-90, tweaking of s23AJ and tightening of thin cap)
  • important accounting issues to ask about
  • key global tax changes.
Materials from this session: