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Expanding Private Business Day 3 - Going Global

Published on 17 Sep 2013 | Took place at Tatersall's Club, Brisbane, QLD

    Day 3 in this series focused on identifying the major issues that arise for an SME when they first go offshore. It covered matters from sending employees abroad to profit repatriation to transfer pricing for SME’s and much more.
    Topics covered included:
  • your offshore planning guide
  • sending employees abroad
  • accidental taxable presence
  • now that we’re global – managing taxation of international profits
  • what does the new transfer pricing regime mean for SME businesses operating internationally?
  • war stories from those who have done it.

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Individual sessions

Your offshore planning guide

Author(s):  Tim HANDS

This paper is a checklist of critical issues to address when planning your overseas business expansion. It covers:

  • local entity types – understand them
  • importance of tax residency rules
  • nature of income and the importance of source
  • CFCs and attribution rules
  • dividend exemptions 
  • disposals and participation exemption.
Materials from this session:

Sending people abroad

Author(s):  Murray HOWLETT

Often the first step, you have to make sure that your key people are looked after and are settled in to do business. This paper covers:

  • planning the first steps for a move
  • residency rules for individuals
  • understanding local taxes
  • salary packaging elements
  • employer registrations and withholdings.
Materials from this session:

Now that we're global - managing taxation of international profits

Author(s):  Muhunthan KANAGARATNAM

This paper examines Australia’s CFC regime and profit repatriation in more detail, including:

  • overview of Australian CFC regime
  • common traps including tainted services and tainted sales income
  • proposed reforms to the CFC regime
  • foreign withholding taxes on profit repatriation – does this result in tax leakage?
  • overview of conduit foreign income and impact on resident and non-resident investors.
Materials from this session:

What does the new transfer pricing regime mean for SME businesses operating internationally?

Author(s):  John BLAND

This paper covers:

  • overview of the transfer pricing regime
  • pricing of common transactions including financing, tangible goods and PEs
  • documentation requirements including acceptable approaches for SME business
  • how it all comes together in the new International Dealings Schedule.
Materials from this session: