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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
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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 Nickless has been a Partner with PwC since 2014, specialising in international tax and transfer pricing. He has advised on a 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 03 July 2026
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This was presented at 3rd Annual Tax Forum .

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Tax administration without borders

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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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