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  Miscellaneous 2008

Foreign entity classification in an outbound investment context and Double tax agreements and fiscally transparent entities

Source: New South Wales

Published Date: 18 Sep 2008

 

This presentation covers:

  • overview of Australian Entities
  • overview of Foreign Hybrid Rules
  • classification of Foreign Entities
  • application of Foreign Hybrid Rules - Current Issues
  • how is a fiscally transparent entity (FTE) treated under double tax agreements?
  • is income derived by or through a FTE eligible for benefits under a DTA?
  • what are the issues on the application of DTAs to FTEs?
  • the OECD view
  • global responses
  • the Australian position(?)
  • case studies.

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Author(s)

Individual Session

Foreign entities - Characterisation and treatment for Australian tax purposes

Author(s): Alison Rodi ATI , David Watkins CTA
Materials from this session:

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