This paper focuses on the recommendations that are relevant for structuring investments by non-residents into Australia, and that impact on Australian corporates with offshore operations. In considering how the recommendations will affect non-residents investing into Australia, the paper discusses the proposals to tax unfranked inter-entity distributions, to tax trusts as separate entities, to extend the scope of the thin capitalisation provisions to all debt and to extend the scope of the capital gains provisions to apply to certain disposals of shares in non-resident companies.
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