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2017 Financial Services Taxation Conference

Published on 08 Feb 2017 | Took place at Palazzo Versace, Gold Coast, National

BEPS and international tax issues impacting on the financial services industry featured at this event, including sessions considering hybrids, branch attribution, transfer pricing and MAAL/DPT. This event also devoted space to recent developments and future directions in a number of key areas including infrastructure, CRS, regulatory capital, TOFA as well as catching up on 2016’s most important cases and rulings.

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Individual sessions

Recent cases and rulings

Author(s):  Joanne DUNNE,  Sarah Sapuppo,  Wendy Lim,  Nick Batten,  Antonella Schiavello

This paper provides a summary of tax judgments from the Federal Court, Full Federal Court and the High Court from January 2016 to the end of December 2016. The table is current to 16 December 2016. The paper also sets out a table of 2016 Rulings current to 16 December 2016.

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Transfer pricing and financial services organisations

Author(s):  Michael JENKINS,  Dianna Govan,  Christine Cornish

This paper covers:

  • related party financing arrangement
  • transparency measures.

 

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Automatic exchange of information and the common reporting standard from the perspective of Australian financial institutions

Author(s):  Anthony Siouclis,  Fred LAW

This paper covers:

  • how CRS works?
  • where to from here?

 

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Division 6c

Author(s):  Siew-Kee CHEN,  Terry MURPHY

This paper covers:

  • genesis
  • legislative structure
  • Division 6C - next steps.
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Perspectives: Future directions in corporate tax

Author(s):  Michelle DE NIESE,  Miranda STEWART

This presentation covers:

  • state of play for corporate tax reform in Australia
  • BEPS, anti-abuse and transparency
  • how does Australia compare?
  • Trump, Brexit and other international uncertainties
  • future corporate tax design: new directions?
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Areas of focus for the financial services industry

Author(s):  Jeremy HIRSCHHORN

This presentation covers:

  • structure
  • the contribution of large corporates
  • industry breakdown
  • concentration risk
  • financial services industry
  • corporate tax transparency report - banking & finance tax performance.
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The changing shape of regulatory capital

Author(s):  Tony FROST,  Bob HERBERT

This paper covers:

  • the market for regulatory capital
  • topical tax issues for ADI issuers
  • topical tax issues for insurance issuers
  • future direction in Australia including the work of the Board of Taxation.
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Latest on the superannuation and related tax issues (large funds)

Author(s):  Bevan Grace

This paper covers:

  • legislative reform
  • ATO developments.

 

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Branch attribution

Author(s):  Julian PINSON

This paper covers:

  • timeline of key documents/events
  • current Australian law and ATO practice
  • RBA vs. AOA
  • international comparison
  • ATO focus areas in bank PE attribution
  • current practical issues and risks, including transfer pricing methodologies.
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The Second Johnson Report - A stocktake on banking recommendations

Author(s):  Rob Colquhoun

This paper covers:

  • the Johnson Report
  • current circumstances
  • specific Johnson recommendations
  • new barriers.
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Transaction costs and M&A deals

Author(s):  Matt BIRRELL

This paper covers the income tax treatment of transaction costs in the context of:

  • a successful M&A transaction
  • “special” situations.
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BEPS for banks and insurance companies

Author(s):  Peter COLLINS,  Matt OSMOND,  Jayde THOMPSON

This paper covers:

  • hybrid mismatch rules
  • the Australian DPT
  • the multilateral instrument - a game changer?
  • thin capitalisation, CFC and cash box rules for banks and insurers.
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The Board of Taxation

Author(s):  Ann-Maree Wolff

This presentation covers:

  • The Board and its reinvention
  • The Board and the 2016-17 Budget
  • other work of the Board
  • tax system improvements; including sounding board.
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