This article discusses topics including ATO amnesty for offshore income, tax disclosure and transparency, transfer pricing documentation - ATO guidance, and OECD discussion draft on preventing...
In Resource Capital Fund III, L.P. v Commissioner of Taxation [2013] FCA 363, the Federal Court held that a Cayman Islands limited partnership...in which 97% of the partnership interests were held...
On 30 January 2013, Gzell J of the New South Wales Supreme Court handed down the decision in CTI Joint Venture Company Pty Ltd v Chief Commissioner of State Revenue [2013] NSWSC 20. The decision...
On 29 June 2012, legislation amending the directors... penalty (DP) provisions in Division 269 of Schedule 1 to the Taxation Administration Act 1997 (Cth) (TAA) and associated measures was enacted...
On 27 June 2012, the Commissioner of Taxation (Commissioner) issued Taxation Ruling TR...2012/5 (Ruling) (previously issued as Draft Taxation Ruling TR 2011/D8), dealing with section 254T of the...
The following articles provide an overview of the recent developments in relation to the taxation of
The Commissioner issued Practice Statement Law Administration PS 2012/2 on 28 June 2012. PS LA 2012/2 sets out the Commissioner's approach to determining from which entity he will seek to recover
On 21 December 2011, the Commissioner of Taxation issued Draft Taxation Ruling TR 2011/D8 (Draft TR) on 'Section 254T of the Corporations Act and the assessment and franking of dividends paid
On 21 June, the Australian Tax Office (ATO) issued two draft 'fact sheets' relating to the taxation of the payment of dividends. This follows amendments to section 254T of the Corporations Act...
On 4 March 2011, the Australian Government released a discussion paper on Improving the taxation of trust income (Discussion Paper). This followed the announcement by the Assistant Treasurer on...
The Australian Taxation Office (ATO) issued on 1 December 2010 2 final Taxation Determinations (TD2010/20 and TD2010/21) and 2 draft Taxation Determinations (TD2010/D7 and TD2010/D8) concerning the...
A number of Federal Court and the Full Federal Court (FFC) decisions were handed down in 2010 which deal with the application of the general anti avoidance provision in Part IVA of the Income Tax...
On 1 September 2010, the Federal Court of Australia (Katzmann J) handed down a decision in Dye v Commonwealth Securities Limited (No 5) [2010] FCA 950 (Dye). The Court in Dye reviewed the decision...
On 28 June 2010 Tax Laws Amendment (2010 GST Administration Measures No. 2) Act 2010 (Cth) (the Act) was given Royal Assent. The Act establishes the legislative framework for entities which are...
Australia, together with other members of the Organisation for Economic Co-operation and Development (OECD), has entered into Tax Information and Exchange Agreements (TIEAs) with a number of...
The International Tax Agreements Act (No. 1) 2010 (Cth) has enacted into Australian domestic law Australia...s new Double Tax Agreement with New Zealand (DTA). This article highlights some of the...