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Issues facing parents and subsidiaries in the current international tax climate

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Published on 01 Jun 15 by "THE TAX SPECIALIST" JOURNAL ARTICLE

Multinationals with an Australian connection, whether Australian-based multinationals or foreign multinationals with a presence in Australia, face a range of taxation challenges. This article considers a number of such challenges. The article begins with an overview of the current tax climate for multinationals. The author then examines cross-border financing considerations for parents and subsidiaries, looking at hybrid financing, issues in relation to s 25-90 of the Income Tax Assessment Act 1997, as well as certain foreign exchange issues.

The article then considers some transfer pricing considerations in light of the Chevron case (the decision in which is currently reserved), the possible impact of the reconstruction provision in s 815-130 of the 1997 Act, and expanded documentation requirements. The article concludes with some thoughts on dealing with reputational risk, tax risk management and preservation of legal professional privilege.

Author profile

Peter McCullough
Peter is the Global Practice Head Tax of Ashurst based in Sydney. Prior to joining Ashurst in 2010, Peter was a partner in the tax practice of Ernst & Young. He has over 27 years of experience advising on a wide range of Australian and international income tax matters, dealing with clients across a broad range of industries. Peter has presented at conferences in Australia and overseas on domestic and international tax issues, is an author of the LexisNexis publication Corporate Tax: Finance, Transactions, Distributions, and has written articles and tax commentary in a number of other professional publications. - Current at 01 June 2015
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