Since the Ralph Report of the late 1990s, the Australian international tax rules have been subject to ongoing reforms. This paper aims to analyse the practical implications for both inbound outbound investors of some recent legislative reforms, court cases, overseas developments and announced future reforms, including:
- tax planning since NITA
- international tax implications of the 2005/06 Federal Budget
- cross border royalty arrangements post McDermott Industries - withholding tax or business profit?
- UK treatment of hybrids - what is the impact for us?