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TR 2007/D5 paper
Published on 19 Sep 07 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE
This paper considers the Commissioner’s position under TR 2007/D5. Specifically, its purpose is:
- to provide an overview of the Commissioner’s draft views of the application of Division 11A to the assignment of copyrigh
- to consider whether the Commissioner’s approach to the application of Division 11A to a payment that is in respect of an assignment of copyright is arbitrary.
Author profiles
Justin Cherrington
Justin is a partner at Malleson Stephen Jaques’ Melbourne Office where he specialises in income tax issues. He has been closely involved in all manner of tax work including corporate restructures, major acquisitions and international tax issues. Justin specialises in all aspects of corporate taxation, including dividend imputation, capital gains tax, capital distributions and employment related tax issues. - Current at 23 July 2007James Willis
James is a solicitor with Mallesons Stephen Jaques. - Current at 23 July 2007
This was presented at International Tax Masterclass .
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Foreign hybrid entity rules - close but not close enough
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Changes to the foreign tax credit regime - a high level summary
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Thin capitalisation - a selection of issues
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Withholding tax considerations
Author(s): Justin CHERRINGTON, James WILLISMaterials from this session:
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Interpretation of double tax agreements
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Substantial equipment
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Strategies for managing offshore taxation obligations and risks
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The new withholding obligations
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