Australia’s international tax integrity rules continue to evolve with new measures announced in the Government’s October 2022 Budget and the ongoing development of the OECD’s BEPS 2.0 proposals. However, a number of anti-avoidance measures from the original BEPS package are reaching a more mature state as corporate groups have adjusted to their implementation and the ATO has undertaken enforcement activities.
This session reflects on the current state of play across a range of international tax anti-avoidance considerations, including:
- Learnings from implementation of the MAAL and DPT, how they affected multinational structures and practical experience in dealing with the ATO
- Views on the application of Part IVA to restructuring activity undertaken in response to these rules; and
- Effectiveness of the Multilateral Instrument in preventing treaty shopping, including relevant considerations in thinking about the principal purpose test.