Australia: Tax Treaties

Retaliatory tax provisions contained in H.R. 1, the "One Big Beautiful Bill Act" that recently passed the US House of Representatives, if enacted, would drastically impact common cross-border transactions, including US operations of foreign multinational groups and inbound investments.

Update on key developments in taxation law for accountants and participants in the tax advice industry up to mid-May.

Key developments in taxation law for accountants and participants in the tax advice industry up to mid-late April.

Open market strategy brings opportunities in the form of tariff reductions and preferential export arrangements.

Changes introduced by this double tax treaty will impact current structures and future deals involving German entities.

In summary, Treasury states that the recharacterisation results in "taxation distortions" and that the federal government "is considering measures which remove the tax advantages of stapled arrangements".

The OECD Global Forum's peer review process is now underway to check the progress of implementation of the International Tax Standard

On 11 May 2010, the Australian Federal Government announced as part of the Budget that it will phase down Australian interest withholding tax arising in respect of interest paid by financial institutions on certain offshore borrowings, with effect from the 2013-14 income year, a move that presents some opportunities, challenges and uncertainties for debt capital raisings by financial institutions operating in Australia.

The Australian Government announced the proposed introduction of the RSPT, a tax on the 'super profits' associated with the extraction of non-renewable resources.