This presentation covers:
- set tone for the day – “it’s about the context”:
- recent history, i.e. since 2001
- current issues and developments
- crystal ball gazing
- not designed to analyse issues:
- role of following presentations
- focus on developments for corporates:
- other fundamental changes for individuals, eg section 23AG, temporary residents etc
- fundamental premise of international tax:
- outbound – profits/gains from conduct of active foreign business with third parties not subject to Australian tax on:
- derivation (CFC rules and section 23AH)
- repatriation (section’s 23AJ and 23AH)
- exit (AFBAP and section 23AH)
- distribution to non-residents (CFI)
- outbound – profits/gains from conduct of active foreign business with third parties not subject to Australian tax on:
- inbound – ensure an “appropriate” Australian sourced profits/gains subject to Australian tax:
- transfer pricing
- treaty model
- capital gains on taxable Australian property.