With the Court in McDermott finding that ‘you don’t have to be here to be here’ for PE purposes, this presentation examines the PE related issues:
- insights into consequences for internationals PE tax planning including Australia withholding tax implications for Singapore entities and what does the case mean for hiring arrangements and cross border leases
- implications for PE royalty arrangements governed by other treaties
- comparison of the Singapore treaty with other treaties and whether the existence of a treaty really matters
- why the ATO does not want you to have a PE and what action do we expect from the ATO?