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  International tax & business Thin capitalisation TOFA

The attribution of income, losses and outgoings to foreign permanent establishments of Australian banks

Source: QLD

Published Date: 13 Feb 2013

 

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This paper covers:

Australian outbound perspectives:

  • the domestic law framework: s 23AH, FITO rules and withholding tax rules
  • relevance of tax treaties and OECD guidelines to the attribution of profits to a foreign branch
  • the effect of intra-entity dealings (Max Factor decision, ATO rulings, treatment of intra-entity risk transfers)
  • Australian implications of capital attribution rules in foreign jurisdictions
  • what difference would adopting a functionally separate entity approach make?

Australian inbound perspectives:

  • the tax classification of the Australian branch
  • the recognition of intra-entity dealings
  • interaction between domestic rules and treaties
  • potential interaction with other rules, especially thin capitalisation and withholding tax
  • potential alternatives and approaches adopted in other jurisdictions.
Author(s)

Individual Session

The attribution of income, losses and outgoings to foreign permanent establishments of Australian banks

Author(s): Ian Fullerton CTA
Materials from this session:

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Details

  • Published By: Ian Fullerton CTA
  • Published On:13 Feb 2013
  • Took place at:Hyatt Regency Sanctuary Cove, Gold Coast

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International tax & business Thin capitalisation TOFA Transfer pricing 2013

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