New Zealand

Details

  • Service: Tax
  • Type: Business and industry issue
  • Date: 21/11/2011

Contact us

Kim Jarrett
Partner - Transfer Pricing
KPMG
Phone: +64 9 363 3532

kmjarrett@kpmg.co.nz

 

John Cantin
Partner - Tax
KPMG
Phone: +64 4 816 4518

jfcantin@kpmg.co.nz

Tax

Our tax advisory team has the skills and commitment to help you to be competitive and compliant in all areas of business tax.

Taxmail - Recent Australian tax developments 

Issue 1, November 2011

 

Recent actions by the Australia Taxation Office (ATO), in response to losses in high profile transfer pricing cases, are a cause for concern. 

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The ATO has indicated that it will continue to target Australia operations that make losses over a prolonged period, even though the Australian Courts have ruled there are valid non-tax reasons for doing so.

 

The ATO may impute an “implied service fee “ (to reflect the benefit to the wider group of building Australian market share, the result being a foreign parent having to support its Australian subsidiary).

 

In addition to transfer pricing developments, changes proposed to the taxation of Australian branches will have implications for the approach adopted by New Zealand.

 

The ATO’s stance on the 183-day rule, in the tax treaty, for creating an Australian taxable presence will come as a shock to many NZ business that provide expertise to their Australian parents (or subsidiaries).

 

If you have any questions on the above, please speak to your usual KPMG advisor or contact:
 

Kim Jarrett
Partner - Transfer Pricing
KPMG
Phone: +64 9 363 3532

kmjarrett@kpmg.co.nz

John Cantin
Partner - Tax
KPMG
Phone: +64 4 816 4518

jfcantin@kpmg.co.nz

Taxmail - Comment on topical tax issues from KPMG NZ Tax. 

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