21-30 of 140 results
Thin cap: debt deduction creation regime
In this insight, we analyse the new debt deduction creation regime and discuss its potential implications. ...
Tax Summit 2022: Capital Management and M&A
At the annual Tax Institute Tax Summit, Partner Joseph Power and Managing Associate Jay Prasad delivered a paper on 'Capital Management and M&A'. It examines the new proposed tax integrity rule for franked distributions funded by capital raisings, the decision in Aurizon and capital contributions, how the ATO's views on demergers have (re)shaped the demerger landscape and some tips and traps when paying a special dividend in connection with a scheme of arrangement. ...
Latest constitutional challenge to notional GST fails
Two recent decisions - Hornsby Shire Council v Commonwealth; and Landcom v Commissioner of Taxation - have rejected constitutional challenges to the notional goods and services tax (GST) voluntarily paid by the Commonwealth, states, local councils and statutory authorities. ...
Closing valuation gaps, unlocking value
The current Australian M&A landscape continues to be marked by a tough valuation environment, with bid-ask spreads, interest rate uncertainty and an uncertain macroeconomic backdrop making completion of transactions difficult. ...
Diverted profits tax exposure draft Bill and explanatory memorandum released
Exposure draft legislation and explanatory materials for a diverted profits tax have been released by the Federal Government Targeted at multinational groups transferring profits to offshore associates the measures will give the Commissioner of Taxation a power to issue assessments at a punitive ...
Linklaters Insights: A cross-border guide to starting a business
Our global alliance partner Linklaters has compiled a guide for foreign investors who are looking to start a business in selected jurisdictions ...
Federal Budget 2023–24: five key takeaways for general counsel
Here is our take on the essential issues for General Counsel arising from the Federal Budget (Budget) 2023-24. ...
Changes to the tax treatment of 'exploration': the journey continues
In the 2023 Federal Budget, the Government announced that legislation would be enacted to apply the narrow meaning of 'exploration' for PRRT purposes. This will be retrospective legislation as it will apply the narrow meaning of exploration for PRRT purposes with effect from 21 August 2013. ...
Treasury proposes new anti-avoidance measure for intragroup payments connected with intangibles in low-tax jurisdictions
The Federal Government is proposing to deny the ability of significant global entities to deduct payments relating to intangible assets connected with low corporate tax jurisdictions. ...
A significant revamp of our thin capitalisation rules is on the horizon
On 16 March 2023, Treasury released an Exposure Draft of the legislation to amend Australia's interest limitation rules—the thin capitalisation rules—contained in Division 820 of the Income Tax Assessment Act 1997 (Cth) (the 1997 Act). ...