Source: The Tax Specialist Journal Article
Published Date: 1 Mar 2017
Australia's multinational anti-avoidance law (MAAL) was introduced to counter the erosion of the Australian tax base by multinational entities. This article explores the nature of Australia's attack on the cross-border transactions of multinational enterprises (MNEs) under the MAAL. It explains the key relevant statutory provisions of the MAAL and where this law sits in relation to the broader international tax framework which the government has committed to shape. It explores how MNEs may be similarly impacted by the new diverted profits tax measures, which was recently introduced into parliament and will commence on 1 July 2017. It describes a field of study which can help explain how and why the ATO has announced that it is reviewing many more taxpayers than were initially described by the government as targets of the law.
More by Greg Weickhardt
Seat 1A on the digital tax plane: Chasing source - or chaos? - Presentation 15 Oct 2020
Seat 1A on the digital tax plane: Chasing source - or chaos? - Video 15 Oct 2020
Seat 1A on the digital tax plane: Chasing source - or chaos? - Audio 15 Oct 2020
The new reality - Australia's cross-border tax environment - Presentation 23 Nov 2016
Coping with cross-border attack: TP, MAAL, hybrid, PE, and related law changes - Presentation 05 Oct 2016
More by Peter Collins
Alternative Assets Insights: Imported hybrid mismatches - Journal 01 Jun 2021
Alternative assets insights: Expansion of the definition of significant global entity - Journal 01 Aug 2020
Alternative assets insights: Glencore v FCT: Transfer pricing decision - Journal 01 Dec 2019
Related party financing - Paper 26 Oct 2017
BEPS for banks and insurance companies - Paper 08 Feb 2017
The new reality - Australia's cross-border tax environment - Presentation 23 Nov 2016
BEPS and international tax: The new reality paper - Presentation 26 Oct 2016
The new reality of international tax - Paper 26 Oct 2016
Coping with cross-border attack: TP, MAAL, hybrid, PE, and related law changes - Presentation 05 Oct 2016
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
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.
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