• Service: Tax, Global Indirect Tax, Global Transfer Pricing Services, Global Compliance Management Services, International Tax
  • Type: Regulatory update
  • Date: 2/27/2014

Australia - Sovereign immunity exemption, PRRT, technology-related withholding, insurance duty 


February 27: The KPMG member firm in Australia prepared reports on the following developments (read the February 2014 reports by clicking on the hyperlinks provided below):

  • Sovereign immunity exemption remains nebulous - A December 2013 Treasury press release confirmed an additional 48 un-enacted tax measures would not proceed. One of the measures concerns the codification of the sovereign immunity exemption (currently provided to foreign governments and their investment bodies in relation to passive Australian investment income).

    Read a February 2014 report

  • PRRT - The expanded petroleum resource rent tax (PRRT) commenced with effect from 1 July 2012 and has a fixed 30 June year-end. Taxpayers need to be prepared to file the starting base return and first PRRT return by 1 June 2014 for a PRRT liability for the 2012/13 year (unless required to pay a quarterly installment in respect of the 2013/14 year, for which an earlier due date will apply).

    Read a February 2014 report

  • Withholding on technology-related payments - Establishing whether particular Australian payments to foreign recipients relating to technology fall within the meaning of “royalty” for tax purposes (and therefore subject to withholding tax) can be a difficult proposition. The two key public taxation rulings, IT2660 and TR93/12, have generally been used as guidance, but were released in the early 1990s. Technology and business delivery models have advanced considerably since then, and it has become increasingly challenging to apply that guidance.

    Read a February 2014 report

  • Australian insurance duty - Insurance duty is a significant source of revenue for the states and territories, including New South Wales, Queensland, and Victoria. Stamp duty law is completely different from Australian income tax rules and can be extremely complex to navigate—because different “classes” of insurance have different rates of duty, and the liability to pay can switch between the insurer and the insured

    Read a February 2014 report

  • Global tax transparency - The combination of the global transparency and BEPS initiatives and real-time compliance initiatives at home is directed to forcing global organisations to reassess their tax risk appetite by reference to both reputational and financial risk, with detection by tax revenue authorities a given.

    Read a February 2014 report

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