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An update on changes to Australia’s international tax system - Inbound investment paper

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Published on 18 May 10 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This paper covers:

  • Myer/TPG overview
  • the revenue/capital distinction
  • treaty benefits and fiscally transparent entities.

Author profiles

Anthony Clemens
Tony is a Senior Tax Partner of PricewaterhouseCoopers, specialising in international taxation. He has a role of advising many of the clients of the firm with international tax related transaction. He has been a partner for 24 years and specialises in cross border transactions and international financing. - Current at 22 November 2005
Click here to expand/collapse more articles by Tony CLEMENS.
Jonathan Malone
Jonathan Malone, CTA, is a Partner in PwC’s Global Tax Practice with over 20 years’ experience as a corporate tax adviser, specialising in international tax, M&A, cross-border related party arrangements and tax policy considerations. Jonathan advises global companies on their operations in Australia, along with the tax implications arising from cross-border transactions. His work with clients on BEPS related topics includes advising on Pillar 2, interest limitation rules, the multilateral instrument, anti-hybrid rules, intangibles measures, Australia's multinational anti-avoidance law and Australia's diverted profits tax. - Current at 14 February 2023
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James Nickless
James has been a Partner with PwC since 2014, specialising in international tax and transfer pricing. He has advised on wide variety of cross border transactions, mergers and acquisitions, and tax controversy matters.  His unique skillset allows him to advise on cross border transactions holistically, combining international tax and transfer pricing skills.  James chairs PwC's thin capitalisation technical panel - Current at 20 January 2026
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This was presented at 3rd Annual Tax Forum .

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Australia's international tax system - Outbound investment

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Author(s):  Dale BOCCABELLA

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Liquidations

Author(s):  Richard J FRIEND

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Tax administration without borders

Author(s):  Howard ADAMS,  Glenn WILLIAMS

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An update on changes to Australia's international tax system - Inbound investment

Author(s):  Tony CLEMENS,  Jonathan Malone,  James Nickless

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Thin capitalisation, transfer pricing and debt deductions

Author(s):  Christian HOLLE,  James Nickless,  Robert PFEIFFER

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GST - The changes operating from 1 July 2010

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