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The secret sauce of source paper

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DisclaimerThis material is copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
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 18 Sep 19 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This paper covers:

  • rationale of the deemed source rule
  • the history of the rule
  • a brief survey of Australian source rules
  • the deemed source rule in operation
  • observations on the deemed source rule
  • exceptions to the deemed source rules.

Author profiles

Abdol Mostafavi CTA
Photo of author, Abdol MOSTAFAVI Abdol Mostafavi is a Partner in the Business Tax Services group at Deloitte, and is based in Sydney. Abdol has over 21 years of experience in corporate and international tax, having advised a wide range of multinational clients in the financial services, real estate, transport, infrastructure services, and utilities sectors. - Current at 10 June 2019
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David Watkins CTA
David Watkins, CTA, has over 35 years experience in corporate income tax at KPMG, Deloitte and Gilbert + Tobin. Particular areas of interest are global and Australian tax policy, consultations and submissions associated with new and emerging tax law, international tax and double tax treaties. David has lived and worked in Malaysia, Singapore and New York. - Current at 20 March 2026
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The secret sauce of source

Author(s):  Abdol MOSTAFAVI,  David WATKINS

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Cross border funding arrangements

Author(s):  Sarah Stevens

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