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  Corporate tax 2021

Corporate residency and private groups

Source: South Australia

Published Date: 28 Apr 2021

 

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This paper covers:

  • Quarantining the profits of the foreign entity at the foreign corporate tax rate (subject to Australia's CFC rules and transfer pricing regime)
  • Accessing the dividend exemption under Subdivision 768-A ITAA 1997
  • Accessing CGT reductions under Subdivision 768-G ITAA 1997
  • Application of s23AH branch exemption to foreign' subsidiaries
  • Determining the members of a tax consolidated group and whether foreign subsidiary members may be considered part of an Australian group depending on where decisions are made
  • Whether the CFC rules apply to the entity and implications for common foreign hybrid' flow through entities
  • Application of Australia's double tax treaties.
Author(s)

Individual Session

Corporate residency and private groups

Author(s): Phil Shepherd CTA
Materials from this session:

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Details

  • Published By: Phil Shepherd CTA
  • Published On:28 Apr 2021
  • Took place at:Novotel Barossa Valley Resort

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