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The expanding offshore client
Published on 01 Sep 17 by "TAXATION IN AUSTRALIA" JOURNAL ARTICLE
Australia’s tax system contains complex rules for Australian entities that wish to expand offshore. The rules can be a minefield and often present difficulties for tax advisers, particularly where they involve applying Australian tax concepts in foreign jurisdictions. This article is intended to provide an overview of the different rules that can apply to Australian entities expanding offshore. While the focus of the article is on offshore investments via a corporate entity, specific issues regarding investments through non-resident trusts are also discussed. The article opens with discussion of basic concepts, including residency and types of entity. The article then discusses in detail what is involved in expanding offshore through a corporate entity, including discussion of the CFC rules. The article concludes with a briefer examination of expansion offshore through a trust.
Author profile
Cameron Blackwood ATI
Cameron Blackwood, ATI, is the Head of Tax at Corrs and is a leading transactional tax expert, specialising in mergers, acquisitions, and restructures. Having advised several of Australia’s largest taxpayers, Cameron’s expertise includes cross-border issues and all aspects of employee share schemes. He has significant experience acting for public and private companies on capital management, including capital raising, return of capital, special dividends and buy-backs and debt raisings. He regularly presents at The Tax Institute and the Corporate Tax Association on M&A, management incentive plans and international tax issues and demergers. Cameron has been recognised as a leading lawyer by legal directories and publications including Chambers, The Legal 500 Asia Pacific and Best Lawyers for Tax in Australia. - Current at 30 May 2024
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