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International Tax Day

Published on 08 Aug 2019 | Took place at RACV City Club, VIC

This event covers:

  • residency - individuals
  • residency - corporate
  • cross border funding arrangements and anti-hybrids
  • recent cases
  • ATO focus
  • transfer pricing.

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Individual sessions

Recent Cases – International aspects of the RCF IV and BHP Billiton Full Federal Court decisions

Author(s):  Andrew BROADFOOT

This paper covers:

  • the BHP Case
  • the RCF IV Case.

 

Materials from this session:

Residency – Individuals (and trusts)

Author(s):  Neil Brydges,  Sam Campbell,  Kelvin Yuen

This paper covers:

  • Australian tax residence 
  • Harding’s case – Full Federal Court’s decision and impact
  • what of the ATO’s appeal to the High Court?
  • Handsley v FC of T 
  • Board of Taxation – consultation guide and report.
  • providing direction over the important or, not important variables, but you should do it anyway?
  • residency of a trust.
Materials from this session:

Residency – Corporate

Author(s):  Daniel Diaz

This paper covers:

  • an overview of the Bywater decision and its history 
  • the ATO’s views regarding central management and control
  • risks of, and responses to, the ATO’s current views.

 

Materials from this session:

ATO focus

Author(s):  Anna Longley

This presentation covers:

  • assurance and compliance programs
  • international risks.

 

Materials from this session:

Transfer pricing

Author(s):  Michael JENKINS

This presentation covers:

  • economic and commercial context
  • evolution of transfer pricing
  • Australia’s transfer pricing rules
  • transfer pricing disputes
  • current compliance issues and PCGs.
Materials from this session: