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Foreign entity classification in an outbound investment context and Double tax agreements and fiscally transparent entities presentation

Member Price: Free
Non Member Price: $15.00

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Published on 18 Sep 08 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This presentation covers:

  • overview of Australian Entities
  • overview of Foreign Hybrid Rules
  • classification of Foreign Entities
  • application of Foreign Hybrid Rules - Current Issues
  • how is a fiscally transparent entity (FTE) treated under double tax agreements?
  • is income derived by or through a FTE eligible for benefits under a DTA?
  • what are the issues on the application of DTAs to FTEs?
  • the OECD view
  • global responses
  • the Australian position(?)
  • case studies.

Author profiles

Alyson Rodi ATI
Alyson is a Tax Partner at Deloitte in Sydney specialising in International and Corporate Tax. Alyson has over 20 years experience advising clients on inbound and outbound cross-border transactions including tax-effective cross-border financing and profit extraction strategies, the application of double tax treaties, the applicability of Australia's foreign accruals rules and potential foreign tax issues. In addition to Alyson's extensive Australian experience, Alyson also has experience working in the international tax groups of Deloitte's London and Dublin offices and working for a major London law firm. - Current at 29 January 2015
Click here to expand/collapse more articles by Alison RODI.
David Watkins CTA
David Watkins, CTA, has over 35 years experience in corporate income tax at KPMG, Deloitte and Gilbert + Tobin. Particular areas of interest are global and Australian tax policy, consultations and submissions associated with new and emerging tax law, international tax and double tax treaties. David has lived and worked in Malaysia, Singapore and New York. - Current at 20 March 2026
Click here to expand/collapse more articles by David WATKINS.

 

This was presented at International Tax Masterclass .

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