The (accidental) outbound tax adviser
Published Date: 20 May 2025
This article is a helicopter view of the relevant issues for outbound investment by small-tomedium enterprises and larger private groups which expand their operations overseas. This process should involve choosing the right entity structures, transaction types and jurisdictions, managing tax residency and source rules, complying with special rules like the controlled foreign company and transferor trust regimes, considering thin capitalisation and the transfer pricing rules, and optimising franking credit and foreign tax offset entitlements, all while not potentially running afoul of the general anti-avoidance rules. The results may appear intimidating for advisers who do not routinely handle these sorts of issues in their general practice, so the authors hope that this article may provide useful insights to help with the identification of such issues before they become a problem for clients, and to highlight when more specialist advisory help may be required.
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
Details
- Published By: Michael Cranston, Bruce Collins CTA
- Published On:20 May 2025
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