Miscellaneous 2008

Foreign entity classification in an outbound investment context and Double tax agreements and fiscally transparent entities

Source: New South Wales

Published Date: 18 Sep 2008

 

This presentation covers:

  • overview of Australian Entities
  • overview of Foreign Hybrid Rules
  • classification of Foreign Entities
  • application of Foreign Hybrid Rules - Current Issues
  • how is a fiscally transparent entity (FTE) treated under double tax agreements?
  • is income derived by or through a FTE eligible for benefits under a DTA?
  • what are the issues on the application of DTAs to FTEs?
  • the OECD view
  • global responses
  • the Australian position(?)
  • case studies.

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Individual Session

Foreign entities - Characterisation and treatment for Australian tax purposes

Author(s): David Watkins , Alison Rodi

Details

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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Miscellaneous 2008

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