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International Masterclass 2018

Published on 19 Sep 2018 | Took place at Four Seasons Sydney, Sydney, NSW

This event presented by leading international tax experts provided an understanding of the continuing changes in the international tax arena relating to Australia. The day consisted of detailed presentations and discussions of recent changes and developments (such as the forthcoming anti-hybrid laws, the complex RCF case and the impact of the recently released Australian Taxation Office guidance on corporate tax residency). The focus was on the practical impact of such changes and the commercial issues that arise. There was also a presentation by senior Australian Taxation Office officials on the changing international tax landscape and the international tax matters that are on their radar.

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Individual sessions

CFC rules: Modern history and some interesting case studies

Author(s):  Craig Marston

This paper covers:

  • modern history
  • brief overview of CFC rules.
Materials from this session:

The RCF IV Decision – Australian Taxation of limited partnerships, and the practical implications for investors

Author(s):  Andrew SHARP,  Peter MCCULLOUGH

This paper covers:

  • limited partnerships generally
  • Australian treatment of foreign limited partnerships and limited partners
  • Division 5A
  • some background – the RCF III decision
  • RCF IV & V
  • the appeal.
Materials from this session:

Demystifying Australia’s hybrid mismatch law

Author(s):  Andrew NELSON,  Britta Perry

This paper covers: 

  • operation of the hybrid mismatch measures
  • common concepts underlying the hybrid mismatch measures.
Materials from this session:

BEPS multilateral instrument – Now a reality

Author(s):  David WATKINS,  Isabelle Mac Innes

This paper covers:

  • introducing the MLI
  • applying the MLI to a particular double tax treaty
  • post ratification events
  • post-MLI treaty interpretation and application
  • MLI key measures overview
  • adoption of the MLI by Australia
  • Australia's double tax treaties impacted by the MLI
  • MLI status around the world
  • some looming MLI issues.
Materials from this session:

Who’s in control?

Author(s):  David ANDERSON,  Emily Clinch

This paper covers:

  • concepts of control
  • control under the Tax Act
  • the emergence of ‘negative control’ and its practical application to tax matters.
Materials from this session:

Practical application of the diverted profits tax provisions

Author(s):  Antony Faisandier,  Angela Danieletto,  Peter Algar,  Edwin Baghdasarayan,  Carynne Howitt

This paper covers:

  • overview of the DPT 
  • practical issues in application of DPT.
Materials from this session: