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Topical tax treaty issues for the financial sector presentation

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Published on 13 Feb 13 by NATIONAL DIVISION, THE TAX INSTITUTE

This presentation covers current tax treaty issues of interest to the finance sector focusing mainly on recent OECD work.

Issues covered include:

  • the international status of the OECD attribution work, including its rejection by the UN
  • OECD work on the definition of permanent establishment
  • OECD work on beneficial ownership
  • treaty treatment of trusts and partnerships
  • relationship of treaties and domestic law.

Author profile

Prof Richard Vann
Richard is Challis Professor of Law at the University of Sydney and has taught at Harvard and NYU Law Schools and the Universities of Amsterdam, London and Oxford. Richard has worked in the past at the IMF and OECD and held many Government consultancies in Australia and elsewhere. He has been a consultant for specialist tax firm Greenwoods & Herbert Smith Freehills since 1985. Richard specialises in corporate and international taxation on which he has published widely both in Australia and internationally. - Current at 15 June 2022
Click here to expand/collapse more articles by Richard J VANN.

 

This was presented at 2013 Financial Services Tax Conference .

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Individual sessions

Topical tax treaty issues for the financial sector

Author(s):  Richard J VANN

Materials from this session:

The attribution of income, losses and outgoings to foreign permanent establishments of Australian banks

Author(s):  Ian FULLERTON

Materials from this session:

Transfer pricing and funds management

Author(s):  Damian PRESHAW

Materials from this session:

Emerging regional issues (funds management)

Author(s):  Daryl CHOO,  Brian CHAMBERS

Materials from this session:

The shifting Part IVA landscape

Author(s):  Larry MAGID,  James PETTIGREW

Materials from this session:

Australian Taxation Office audits, risk identification, dispute

Author(s):  Ashley KING,  Andrew MCLOUGHLIN

Materials from this session:

GST and RITCs on trustee services

Author(s):  Amelia O'Rourke,  Bill PACKWOOD

Materials from this session:

Losses

Author(s):  Julian HUMPHREY

Materials from this session:

Capital management of financial institutions and the related tax issues

Author(s):  Tricia HO-HUDSON

Materials from this session:

The Rubik's Cube of tax - An update on trusts

Author(s):  Andrew MILLS,  Matt HARTSHORN

Materials from this session:

New R&D regime in financial services

Author(s):  Jamie MUNDY

Materials from this session:

The promoter penalty regime - How the ATO ia applying it in practice

Author(s):  Bruce COLLINS,  Nathan FIRTH

Materials from this session:

TOFA - A new world of economic substance?

Author(s):  Phillip COLE

Materials from this session:

Income tax case update

Author(s):  Cameron RIDER

Materials from this session:

Asset financing/thin capitalisation/infrastructure update

Author(s):  Steve FORD,  Arash AZIMI

Materials from this session:

MRRT and Carbon Tax: Issues for financiers and funds

Author(s):  Teresa DYSON

Materials from this session:

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