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International Masterclass

Published on 09 Oct 2014 | Took place at Swissotel Sydney, Sydney, NSW

This event presented by leading international tax experts including senior officials from the Australian Taxation Office, provided an understanding of the continuing changes in the international tax arena. The day consisted of detailed presentations and discussions of recent changes and developments, with a focus on the practical impact of such changes and the commercial issues that arise.

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Individual sessions

Tax treaty developments

Author(s):  Richard J VANN

This paper covers:

  • BEPS and tax treaties
  • OECD 2014 update to model tax convention
  • Australian tax treaty developments
  • developments in international transparency.

 

Materials from this session:

Issues arising from the resource capital fund (“RCF”) case

Author(s):  Abdol MOSTAFAVI,  Charlotte Brierley

This paper covers:

  • factual background
  • the judgment at first instance
  • the judgment of the full federal court
  • the aftermath of RCF.
Materials from this session:

Australia and the digital economy: A case study

Author(s):  Alison MARSHALL,  Tim Lynch

This presentation covers:

  • scenario 1: foreign co – Australian subsidiary
  • scenario 2: US Co – no Australian subsidiary
  • scenario 3: US LLC – no Australian subsidiary
  • scenario 4: Luxemburg Co – no Australian subsidiary
  • OECD digital economy BEPS report.
Materials from this session:

The future of hybrid financing in Australia

Author(s):  Craig Church,  Joanne LUGG

This paper covers:

  • what is hybrid financing?
  • a short Australian tax history of hybrids
  • Subdivision 768-A
  • the action 2 paper
  • inbound hybrid financing
  • outbound hybrid financing
  • practical considerations in applying the action 2 recommendations.
Materials from this session:

Future directions in transfer pricing arising under the BEPS recommendations

Author(s):  Lyndon JAMES,  Edin Mahir,  Paul MCNAB,  Annemarie Wilmore

This paper covers:

  • BEPS – the story so far
  • future directions in transfer pricing arising under the BEPS recommendations
  • an Australian perspective.
Materials from this session:

Dealing with a BEPS based tax review

Author(s):  Ermelinda Kovacs,  Fiona MOORE

This paper covers:

  • BEPS action Plan & ATO involvement
  • commencement of a BEPS based review
  • ATO document and information requests directed to the taxpayer
  • functional interviews
  • recommendations for managing a BEPS based review.
Materials from this session: