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Corporate residency and private groups video


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Member Price: $99.00
Non Member Price: $121.00

Publication date: 28 Apr 21 | Source: SOUTH AUSTRALIAN DIVISION, THE TAX INSTITUTE

Abstract:
This video covers:

  • Quarantining the profits of the foreign entity at the foreign corporate tax rate (subject to Australia’s CFC rules and transfer pricing regime)
  • Accessing the dividend exemption under Subdivision 768-A ITAA 1997
  • Accessing CGT reductions under Subdivision 768-G ITAA 1997
  • Application of s23AH branch exemption to ‘foreign’ subsidiaries
  • Determining the members of a tax consolidated group and whether foreign subsidiary members may be considered part of an Australian group depending on where decisions are made
  • Whether the CFC rules apply to the entity and implications for common foreign ‘hybrid’ flow through entities
  • Application of Australia’s double tax treaties.

Purchase individual materials from this session:

2021 Barossa Convention (13 Parts)
Author(s):  Ben Turner

Material from this session:

Author profile

Philip Shepherd CTA
Philip Shepherd, CTA is a is a tax partner at Arcem Advisory, working primarily with complex family groups and mid-market corporates. During his 17 years in practice in mid-tier and big 4 firms, Phil has advised some of South Australia’s most iconic families, helping them navigate through restructures, divestments, acquisitions, succession planning, international tax structuring and ATO reviews. With a background focussing on in-bound corporate groups, Phil has a passion for seeing global business thrive in South Australia; and local businesses succeed off-shore. Phil is a Chartered Accountant, a Chartered Tax Advisor, and winner of the 2021, SME Tax Advisor of the Year Award. - Current at 04 November 2024
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