11-20 of 123 results
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. ...
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). ...
EVs and excise: constitutional challenge to Victoria's electric vehicle road user charge
A constitutional challenge to the Victorian electric vehicle road user charge has brought into sharp focus the balance of taxing rights as between the states and the Federal Government. The case may have broad-ranging implications for federal and state tax bases. ...
Tax disputes series: reaching successful tax settlements
Webinar: Tax Disputes Series: Reaching successful tax settlements ...
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. ...
Is a change (to a stapled structure) as good as a (tax) holiday?
In the second case to consider the general anti-avoidance rule contained in Part IVA since it was amended in 2013, a single judge of the Federal Court has held that the overall restructuring of a loan securitisation business from a corporate group to a corporate group and a separate trust group, which ultimately became a stapled structure, was legitimate and not rendered ineffective for income tax purposes. ...
Shell Energy Holdings v Commissioner of Taxation: the end of the 'exploration' journey
On Friday 9 September 2022, the High Court rejected the Commissioner's application for special leave to appeal against the decision of the Full Federal Court in FCT v Shell. So ends the long journey that was the Commissioner's attempt to confine the meaning of 'exploration' to the mere discovery of a resource. ...