Miscellaneous 2007

The effect of McDermott on our international tax rules

Source: Victoria

Published Date: 12 Oct 2007

 

With the Court in McDermott finding that ‘you don’t have to be here to be here’ for PE purposes, this presentation examines the PE related issues:

  • insights into consequences for internationals PE tax planning including Australia withholding tax implications for Singapore entities and what does the case mean for hiring arrangements and cross border leases
  • implications for PE royalty arrangements governed by other treaties
  • comparison of the Singapore treaty with other treaties and whether the existence of a treaty really matters
  • why the ATO does not want you to have a PE and what action do we expect from the ATO?

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Individual Session

International tax McDermott's case

Author(s): Peter Van Den Broek

Details

  • Published By: Peter Van Den Broek
  • Published On:12 Oct 2007
  • Took place at:Mantra Erskine Beach Resort, Lorne

The material is copyright. Apart any fair dealing for the purpose of private study,

research critisism or review, as permitted under the copyright Act, no part may be rerpoduced by any process without written permission from The Tax Institute.

Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

This material is copyright. Apart from any fair dealing for the purpose of private study., research, critisism or review, as permitted under teh copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.

Unless expressly stated, opininons are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

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