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BEPS – Action Item 2 - Hybrids presentation
Published on 07 Feb 18 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE
This presentation covers:
- Australia’s response - update
- expected timing
- inbound financing
- inbound MRPS – HFI Rule
- reverse hybrid
- imported mismatch.
Author profiles
Manu SRISKANTHARAJAH
Paul Korganow
Paul Korganow, ATI, is the ATO Assistant Commissioner for the International Tax Structuring/BEPS Practice, Public Groups and International. Paul leads an International Tax Structuring team based in Melbourne and Sydney. He is also involved in strategy development and contribution to domestic and multilateral law reform around BEPS. Paul is the ATO Project Lead for BEPS Action 2, the Australian ATO representative at OECD Working Party 11 and represented the ATO on the Board of Taxation Working Group looking at the domestic implementation of the OECD Anti-Hybrid Rules. Paul was previously a Partner at two Big 4 firms in their International Tax and M&A groups.
- Current at
16 February 2018
This was presented at 2018 Financial Services Taxation Conference .
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M&A in financial services
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Mandatory disclosure rules & reporting
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Residence – Central management & control
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The ATO’s approach to significant financial services tax issues
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Mergers and acquisitions in financial services
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Macro economic outlook and implications for taxation
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Restructures, turnarounds and insolvency
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Life and superannuation accounting update
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Transfer pricing post Chevron
Author(s): Julian HUMPHREY, Tim KeelingMaterials from this session:
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Australian tax treatment of foreign investments by Australian collective investment vehicles
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Practical issues for interest withholding tax and section 128F
Author(s): Ian KELLOCK, Bronwyn KIRKWOODMaterials from this session:
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Diverted profits tax
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GST and financial services - The looming battleground
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Australia’s hybrid mismatch rules: Application and interactions
Author(s): Manu SRISKANTHARAJAHMaterials from this session:
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Tax transparency initiatives – The current state of play
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Stapled groups
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