Transfer Pricing – Chevron Case

  Last month, the Australian Taxation Office won a battle with Chevron Australia Holdings Pty Limited (CAH), with the Federal Court finding that the interest rate paid by the Australian resident company to its US subsidiary was not an arm’s length rate. The case considered both the former transfer pricing rules, as well as the current rules which have applied … Read More

In the news

  The Re:think tax discussion paper was released by the Australian government last month, aiming to stimulate discussion on the future of our tax system. A key issue raised in the discussion paper is the challenge the tax system faces from changes in the global economy. Chapter 5 discusses Australia’s relatively high corporate tax rate and the fact that our … Read More

Simplifying transfer pricing record keeping

We discussed Australia’s new transfer pricing regime in our December newsletter. The Australian Taxation Office has since released administrative guidance providing small businesses some relief from the complex and costly task of preparing transfer pricing documentation. The entities that might qualify for simplified record keeping requirements: Small businesses with a turnover of less than $25 million Distributors with turnover of … Read More

CGT rules for non-residents

  Non-residents are only subject to Australian CGT on Taxable Australian Property (TAP). TAP includes: direct and indirect interests in real property situated in Australia business assets used in an Australian branch an option to acquire any of the above a CGT asset elected by an individual to continue to be subject to Australian CGT after they cease to be … Read More

Are you subject to U.S. Tax?

  THE ANSWER MIGHT SURPRISE YOU. As an Australian tax resident, you probably feel that how the US imposes tax on its citizens does not concern you. The reach of the US tax department might be further than you think. The United States is one of only three countries in the world to tax individuals with little regard as to … Read More

Issues to consider when setting up a business overseas

If you are looking to expand your business overseas, be sure to read and take into account the issues raised below, as well as considering the questions asked. What are your plans in relation to the expansion? Do you want to search for more talented people, access more cost-effective human resources, or want to tap into a new/niche market or … Read More

Doing business in Australia

For general information on tax and other regulatory issues facing foreign business looking to trade in Australia, we have prepared a “Doing Business in Australia”.  We hope that it is helpful to you, and would welcome any queries or feedback you may have. Doing Business in Australia – Updated 21 December 2020

Project DO IT – ATO Amnesty for disclosure of offshore income

The Australian Taxation Office (ATO) amnesty on disclosures of assets or income overseas that they have not previously been made aware of  is about to close on 19 December 2014. The ATO initiative  allows taxpayers to disclose assets or income overseas on a “no questions asked” basis. The ATO  will then issue amended assessments to the taxpayer for the years … Read More

Popular press on taxation of multinationals in Australia

Avoidance of Australian tax by multinationals is featuring prominently in newspapers in Australia, with stories of a global tax hunt with tax auditors camped out in the Australian corporate offices of some of the world’s biggest companies. ATO’s global tax hunt: Multinationals under scrutiny for minimisation schemes Joe Hockey eyes Britain’s ‘Google tax’ to boost tax take Joe Hockey confirms … Read More