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Our dedicated international tax professionals assist our clients with their cross-border tax structuring, planning, reporting and risk management.
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The Government released on 2 October 2018 a Treasury Discussion Paper (TDP) which explores a corporate tax system for the digital economy in Australia as announced in the 2018 Federal Budget. The TDP does not provide any recommendations or express a clear preference for any particular measure for taxing the digital economy either on a long-term structural basis or an interim basis. However, it implies that an interim digital services tax may be warranted given the likelihood that no long term global solution is in sight. The TDP is seeking feedback on a series of very open ended questions by 30 November 2018.
On 7 February 2018, the ATO released a draft practical compliance guide (PCG 2018/D2) relating to Australia’s Diverted Profits Tax. Although further work is needed on PCG 2018/D2 and LCG 2017/D7, it is a positive development and will assist businesses to: Calibrate the risk of ATO DPT questions during ATO compliance activities; Prepare for the approaches and issues the ATO will target; Consider proactive approaches to the ATO DPT team if desired, to reduce later controversy risk.
Australia’s Treasurer released on 24 November 2017 an Exposure Draft (ED) of the Treasury Laws Amendment (OECD Hybrid Mismatch Rules) Bill 2017 (TLAB) for consultation. The hybrid mismatch rules will apply to payments made on or after the day six months following the day TLAB receives Royal Assent. We expect the TLAB to be introduced into Parliament in the Autumn 2018 Parliamentary sittings commencing 5 February 2018. Our Tax Alert explains the law in more detail, highlights impacted structures and recommended actions.
Australia’s Adoption of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI)
This Global Tax Alert outlines in detail Australia’s plans to adopt MLI Articles including reserving the right to adopt provisions with regard to the artificial avoidance of PE status in bilateral treaties. In addition, Australia expressly excluded cases involving its general anti-avoidance provisions (e.g., Diverted Profits Tax and Multinational Anti-Avoidance Law) from the scope of the mandatory binding treaty arbitration (MAP) procedures.
On 7 June 2017, Australia and New Zealand participated in the signing ceremony of the Multilateral Convention (MLI) to start the process to implement certain BEPS measures to update the existing network of bilateral double tax treaties. The Australian Government confirmed its adoption positions and reservations on a provisional basis but noted that the MLI will require various processes before it becomes effective - in our view the operation of the MLI changes is therefore unlikely before 2019.