Anti-avoidance Capital Gains Tax (CGT) Debt

Where are we, how did we get here and where are we going? prsentation

Source: Western Australia

Published Date: 5 Aug 2014

 

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)
  • inbound – ensure an “appropriate” Australian sourced profits/gains subject to Australian tax:
    • transfer pricing
    • treaty model
    • capital gains on taxable Australian property.

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Anti-avoidance Capital Gains Tax (CGT) Debt Equity Thin capitalisation Corporate tax International tax & business 2014

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