Anti-avoidance Capital Gains Tax (CGT) Debt

Where are we, how did we get here and where are we going? prsentation

Source: Western Australia

Published Date: 5 Aug 2014

 

This presentation covers:

  • set tone for the day – “it’s about the context”:
    • recent history, i.e. since 2001
    • current issues and developments
    • crystal ball gazing
  • not designed to analyse issues:
    • role of following presentations
  • focus on developments for corporates:
    • other fundamental changes for individuals, eg section 23AG, temporary residents etc
  • fundamental premise of international tax:
    • outbound – profits/gains from conduct of active foreign business with third parties not subject to Australian tax on:
      • derivation (CFC rules and section 23AH)
      • repatriation (section’s 23AJ and 23AH)
      • exit (AFBAP and section 23AH)
      • distribution to non-residents (CFI)
  • inbound – ensure an “appropriate” Australian sourced profits/gains subject to Australian tax:
    • transfer pricing
    • treaty model
    • capital gains on taxable Australian property.

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Details

  • Published By: Mathew Chamberlain
  • Published On:5 Aug 2014
  • Took place at:City West Receptions, WA

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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Anti-avoidance Capital Gains Tax (CGT) Debt Equity Thin capitalisation Corporate tax 2014

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