Global

Details

  • Service: Tax, International Tax
  • Type: Regulatory update
  • Date: 2/11/2014

Australia - Tax sharing arrangements, anti-avoidance regime 

February 11:  The KPMG member firm in Australia prepared reports on the following developments (read the February 2014 reports by clicking on the hyperlinks provided below):
  • Has your tax sharing agreement had its annual service? The Australian Taxation Office (ATO) reissued Chapter 35 of the “receivables policy” relating to the collection of consolidated group liabilities, including the ATO’s approach to tax sharing agreements and of a clear exit of subsidiaries from consolidated groups. While not substantially different, the release serves as a reminder of the need to regularly “service” and “maintain” tax sharing agreements.

    Read a February 2014 report


  • Beneficial ownership: unexploded grenade in the global tax treaty network? Australia (like a number of other countries) has sought to reform its legislative framework in order to make the service offerings of its local funds management industry more attractive to foreign investors.

    Read a February 2014 report



  • Part IVA: The song remains the same… or does it? Part IVA (i.e., Australia’s general anti-avoidance regime (GAAR)) was amended over a year ago, in response to a series of decisions on commercial arrangements that the Australian Taxation Office perceived as “blatant, artificial and contrived” but that the tax authorities were unable to persuade the courts that the arrangements represented Part IVA-type tax avoidance. The courts have since concluded Part IVA can apply to a wholly commercial scheme.

    Read a February 2014 report



©2014 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity. All rights reserved.


The KPMG logo and name are trademarks of KPMG International.


KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever.


The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.


Direct comments, including requests for subscriptions, to us-kpmgwnt@kpmg.com.
For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at:

+ 1 202 533 4366

1801 K Street NW
Washington, DC 20006.

 

Share this

Share this

Subscribe

Subscribe to receive the latest TaxNewsFlash email alerts (you must select the option for TaxNewsFlash)


Already a Subscriber? Login


Not a member? Subscribe now

Contact us