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Alternative assets insights: Foreign superannuation funds and sovereign immunity

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Published on 01 Mar 20 by "TAXATION IN AUSTRALIA" JOURNAL ARTICLE

LCR 2019/D4 provides welcome guidance from the ATO on the new rules limiting concessions available to foreign superannuation funds and the newly codified rules for sovereign immunity.

Author profiles

Luke Bugden
Luke is a Tax Partner at PwC with significant experience in providing Australian income tax consulting advice to a wide range of public and private companies in the infrastructure, utilities and energy industries, alternative assets and both Commonwealth and state government agencies on various projects. Luke brings significant commercial experience with respect to infrastructure projects, including M&A and the development of greenfield projects. Luke also co-leads at PwC the Sovereign Wealth Fund and Foreign Pension Fund practice and has been actively engaged in consultation with the ATO on law design and administration as it relates to the stapled structure changes as well as the foreign pension fund and sovereign wealth fund changes. - Current at 19 November 2020
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Nicholas Rogaris
Nick Rogaris, is a Director at PwC in the Tax and Legal services practice with extensive tax advisory, compliance and transaction experience in the Australian real estate industry. Nick brings over 14 years’ experience in the Australian real estate, infrastructure and corporate tax industry, with particular expertise in inbound Australian real estate investment (Managed Investment Trust (MIT) & non-MIT structures), stapled structures, retirement living, advice and assistance in the areas of structuring and taxation due diligence and advice across a broad range of real estate transactions. Nick is also involved with lobbying efforts on behalf of PwC, including preparation of PwC submissions relating to the Treasury's consultation on stapled structures and the Privatisation and Infrastructure - Australian Federal Tax Framework. - Current at 25 September 2024
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