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2018 National Resources Tax Conference

Published on 24 Oct 2018 | Took place at Perth Convention and Exhibition Centre, WA

This event provided updates on questions of tax transparency, increased complexity in transfer pricing, R&D claims, valuations and Part IVA. Adding to this continued focus, will be sessions on contingent consideration, project combinations and stamp duty as well as evaluating M&A opportunities.

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Individual sessions

Current issues in financing for resource companies

Author(s):  Ian KELLOCK

This paper covers:

  • thin capitalisation
  • hybrid mismatch rules
  • interest withholding tax.

 

Materials from this session:

Asset unitisation

Author(s):  James O'Reilly,  O'Hare Janelle,  Jess Fantin

This paper covers:

  • the fiscal environment
  • alternate approaches to structuring unitisations
  • direct asset unitisation involving UJV
  • direct asset unitisation involving a partnership
  • incorporated unitisation
  • synthetic asset unitisation.
Materials from this session:

Structuring a sale and purchase: Stamp duty on direct vs indirect acquisition

Author(s):  Jinny CHAIMUNGKALANONT

This paper covers:

  • duty on an assets acquisition
  • duty on a share acquisition
  • direct vs indirect acquisition: examples
  • pre-sale restructure.
Materials from this session:

Tax disclosures – Is sunlight the best disinfectant?

Author(s):  Enzo COIA,  Lauren Jones,  Anna Williams

This paper covers:

  • why increased tax disclosures?
  • what data is now disclosed?
  • making disclosures
  • what’s fair?
  • are we fair yet?
Materials from this session:

Petroleum resource rent tax - Implications of third party infrastructure arrangements

Author(s):  O'Hare Janelle,  Ryan Jones

This paper covers:

  • application of PRRT Regulations
  • practical examples.

 

Materials from this session:

Navigating the shifting sands for non-Resident contractors

Author(s):  Matthew POPHAM

This paper covers:

  • tax residency and permanent establishments
  • non-resident contractor withholding tax (NRCWHT)
  • other withholdings
  • summary for non-resident contractors
  • Australian counterparty obligations.
Materials from this session:

The R&D tax incentive - The shifting policy & regulatory landscape

Author(s):  Liz Dallimore

This presentation covers:

  • program overview
  • eligibility criteria
  • R&D policy
  • legislative changes
  • AusIndustry guidance
  • taxpayer alerts
  • Moreton Resources AAT decision
  • substantiation & governance requirements.
Materials from this session:

Part IVA and restructures

Author(s):  Andrew BROADFOOT

This paper covers:

  • Part IVA
  • hybrids and anti-hybrid measures
  • Part IVA and restructure examples
  • thin capitalisation regime and proposed changes.
Materials from this session:

Valuations - Placer Dome and RCF

Author(s):  Philip BISSET,  Luke Furness,  Christie O'Donnell,  John MIDDLETON

This paper covers:

  • recent cases
  • AP energy
  • RCF IV and V
  • GST withholding issues
  • briefs to experts and assumptions.
Materials from this session: