Corporate tax residency - There's no Australian tax payable is there?
Source: The Tax Specialist Journal Article
Published Date: 1 Oct 2020
This article looks back at the historical development of the corporate residency rules including some consideration of the old line of authority (eg Malayan Shipping v FCT) and the newer decisions (eg Bywater Investments Ltd v FCT). This is followed with analysis as to where we are currently at (especially TR 2018/5) and, most importantly, where we might be going in this space. In doing so, the key risk areas are identified and assessed, the central importance of board minutes is considered as is the critical impact of technology, and the interface with treaties, transfer pricing, capital gains tax and the controlled foreign rules is evaluated.
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Details
- Published By: Tim Sandow CTA
- Published On:1 Oct 2020
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