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International Tax Masterclass

Published on 30 Aug 2012 | Took place at RACV Club, Melbourne, VIC

    This Masterclass was aimed at international tax practioners and CFOs/financial controllers of Australian multinationals or foreign companies operating in Australia. The Masterclass aimed to provide a technical review of current issues in both inbound and outbound investment structures. Presented by two of the leading international tax partners in Melbourne, James Strong and Claudio Cimetta it took participants through relevant case studies and examples of international tax planning in practice.
    Topics covered included:
  • James Strong focused on inbound investment with a specific focus on foreign companies investing and making acquisitions in a tax efficient manner and exit strategies. He also presented a mining industry focus on these tax issues.
  • Claudio Cimetta explained outbound investment strategies, with a specific focus on exit options for Australian multinationals.

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

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Individual sessions

Inbound investment - Application of Division 855

Author(s):  James STRONG,  Melanie Cameron

This paper covers the following regarding inbound investment:

  • In what circumstances will I be subject to Australian CGT?
  • When should I use an Australian company versus foreign acquisition company?
  • Debt funding – when is it relevant?
  • What is the impact of the decision in TEC Desert?
  • Does functional currency matter?
  • If I use a foreign company, can I dispose my investment to an Australian purchaser?
  • Are there are any roll-overs available?
  • What happens with branch assets?
Materials from this session:

Outbound investment - Exit strategies

Author(s):  Claudio Cimetta

This presentation covers the following in regard to outbound investment:

  • How does the participation exemption work in practice?
  • Book value or market value method – which is best?
  • Why do active businesses sometimes fail the active asset test?
  • What if there are foreign hybrids in the structure?
  • What happens when a CFC sells a foreign subsidiary?
  • How is a sale of assets or sale of a branch treated?
  • What foreign taxes do I need to be aware of?
  • What is the impact on funding and thin capitalisation?
Materials from this session: