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Are all of your overseas subsidiaries really non-residents? paper

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Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

Published on 21 Sep 17 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This paper covers:

  • the Bywater decision
  • carrying on a business in Australia
  • is ‘central management and control’ controlled by shareholders who are residents of Australia
  • practically demonstrating central management and control and the ATO administrative approach.

Author profiles

Sarah Hickey
Sarah is a Director in Corporate taxes at PwC. Sarah advises Australian and international businesses on structuring and implementing sale transactions, and has experience in acting for both vendors and purchasers. Sarah also has extensive experience in leading tax due diligence processes. She is also a qualified legal practitioner. - Current at 01 January 2014
Click here to expand/collapse more articles by Sarah HICKEY.
Bianca Wood
Bianca is a Tax Director in PwC's Sydney office. Bianca has over 9 years’ experience advising domestic and multinational companies on a range of complex transaction-based issues including financing, acquisitions, disposals and internal group reorganisations. - Current at 25 October 2017

 

This was presented at 2017 International Masterclass .

Get a 20% discount when you buy all the items from this event.

Individual sessions

Supply chains into Australia

Author(s):  Brett Gilshenan,  Michael Anderson,  Christian Chan

Materials from this session:

Are all of your overseas subsidiaries really non-residents?

Author(s):  Sarah HICKEY,  Bianca Wood

Materials from this session:

Key considerations impacting expats and inpats

Author(s):  Terry Hoban

Materials from this session:

Multilateral instrument and treaties

Author(s):  Richard J VANN,  Steven GUO

Materials from this session:

International issues arising - Employee share plans

Author(s):  Sandra BUTH,  Richard WILSON

Materials from this session:

Diverted profits tax

Author(s):  Jarrod Thomas,  Alia Lum,  Nick Maley

Materials from this session:

Further details about this event:

 

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