Increasing use of tax-transparent entities by private groups due to BEPS
Source: The Tax Specialist Journal Article
Published Date: 1 Apr 2016
To date, the effect of the base erosion and profit shifting (BEPS) project is that Australian-owned private companies whose business could be affected by ecommerce are largely able to avoid high rates of foreign taxation. This allows significant deferral of Australian tax liability until the profits from the overseas activities are ultimately released into the hands of Australian resident individuals. This would often involve the use of tax haven subsidiaries of an Australian company, selling into a world market, without a taxable presence in the country of the customer.
The result of implementation of one or more of the action items of the BEPS project may create a situation where Australian private companies' non-resident subsidiaries will increasingly become liable to more foreign taxes than in the past. This article examines the tax-transparent entities that might be available to owners of Australian-owned private companies in several countries, and compares the pros and cons of each.
Sorry, this is subscriber only content.
To gain access to this material and much more - Subscribe Now.
(Note: Members can access Taxation in Australia journal articles without a Tax Knowledge Exchange subscription - please log in to access).
Already a Subscriber? Login now
Already a Subscriber? Login now
Details
- Published By: Robert Gordon CTA
- Published On:1 Apr 2016
The material is copyright. Apart any fair dealing for the purpose of private study, research criticism or review, as permitted under the copyright Act, no part may be reproduced 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.
The Tax Institute
(ABN 45 008 392 372 (PRV14016))
("TTI")
The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009.
Copyright Statement
All materials provided on this site are protected by copyright and are owned by or licensed to TTI.
Except as expressly permitted by TTI or the copyright owner, any person or company who uses this site must not use, reproduce, redistribute, retransmit, publish or otherwise transfer, or commercially exploit, the materials or any information, software or other content, in whole or in part, which is available through this site.
Tags
Share this page