KPMG's analysis of tax issues and developments.
Jeremy Geale and Jeremy Capes discuss the OECD BEPS discussion paper on dispute resolution and the principles used to remove MAP obstacles.
Grant Wardell-Johnson summarises the history of Federal Income Tax and wishes everybody a happy holiday period.
Anthony Seve explains the ATO's simplified guidance to alleviate transfer pricing compliance burden.
Tony Morganti discusses the proposed reforms for PE and enlists the key functioal areas of OECD discussion draft on BEPS Action 7.
David Sofrà examines the government's policy initiative to simplify the application of Superannuation Guarantee Charge post the MYEFO release.
Ben Opie discusses the ATO's release of Taxation Ruling TR 2014/9 following substantial industry consultation.
Jane Rolfe highlights the importance of record keeping and documenting the TP affairs to be eligible for a reasonably arguable position.
Megan Croaker talks about the uncertainty arising from the MBI Properties decision in respect of arrangements other than property leasing.
Grant Wardell-Johnson discusses the significant decline in MYEFO 2014 since the budget due to various Economic Parameters.
Ablean Saoud explains the streamlined filing procedure introduced by IRS to encourage compliance.
Matthew Stutsel teases out some of the implications of the High Court's recent ruling regarding stamp duty.
Jenny Wong discusses the OECD base erosion and profit shifting Action 2 initative to neutralise hybrid mismatch arrangements.
Ross Stephens discusses ATO's views on FX hedging gains/ FX hedging losses and its impact on foreign income tax offsets.
Leonie Ferretter helps businesses prepare for the new KAFTA, and utilise new opportunities for reduced duty rates.
Julian Humphrey shows how the Financial Systems Inquiry Final Report frames the debate on tax reform, but leaves the tax community wanting more.
Mark Smith describes the OECD initiative to develop transfer pricing rules to provide protection against base eroding payments.
Megan Croaker highlights the high court's take and actions in connection to GST on leasing.
Megan Croaker highlights that suppliers of telecommunications, broadcasts and electronic services will be liable for VAT in the EU member state.
Alan Garcia highlights Governments R&D program initiatives to encourage company investments.
Arthur Begetis explains how strategic review of transfer pricing policy can help identify and correct any issues prior to the closure of accounts.
Helen Gilfedder and Amanda Leong discuss the impact of GHP on the interpretation of the R&D legislative provisions.
Natalie Raju analyses the OECD’s proposed changes to the definition of a permanent establishment under the BEPS action plan.
Emma Crause highlights the substantial proportion of the investment management activities relating to the assets of a managed investment trust (MIT).
Jeremy Geale and Amanda Leong observe the ATO’s increased support for the use of declaratory proceedings in tax matters.
Rod Henderson and Jenny Wong highlight the Government's Australia-China FTA and initiative to review the bilateral tax treaty.
Brad Ivens alerts super funds to the new rules allowing the withdrawal of super contributions in excess of the non-concessional contributions cap.
Mark Poole highlights documentation as the relevant evidence in disputing the imposition of an administrative penalty.
Grant Wardell-Johnson, shares the thoughts of Pascal Saint-Amans, the Director of OECD on the G20 Summit held in Brisbane.
Bill Sfikas outlines the questions emerging out of the prospective rules for RTFI assets in the context of tax consolidation.
Jeremy Geale explains how new ASIC class orders will make it easier for listed and unlisted corporates to offer employee share plans.
Maria Lui and Andrew Strutt explain why record-keeping is necessary for research and development (R&D) claims.
Anthony Seve and Jeremy Capes enlist situations where taxpayers may increase compliance risk and uncertainty.
Dermot Gaffney discusses the potential changes that may be announced at the G20 Summit in Brisbane.
Glenn Jackson and Mark Smith address the tax reporting challenges organisations face amidst an ever increasing regulatory changes and requirements.
Graem McClelland highlights the importance of documentation and review of tax fixed asset policy.
Jenny Wong explains the implications for investors of the government's proposed new withholding tax regime for real Australian property.
Minh Dao highlights how proposed amendments to the definition of foreign pension funds could affect access to the MIT withholding regime.
Louise Lovering examines two competing views on the Desalination Technology case.
Michael McAuliffe talks about the potential consequences of increasing the fuel tax through a Tariff Proposal.
Jeremy Geale discusses the ATO's Revised Code of Settlement to encourage settlement and resolution of tax disputes.
Jenny Wong highlights 4 things to consider when investing into Australian real property via limited partnerships.
Mathew Herring throws light on feedstock inputs and eligible R&D expenditure under the R&D Tax Concession.
William Arudsothy highlights the implications for taxpayers when determining the valuation of a lease.
Stuart Dall’s response to Australian Taxation Office Second Commissioner, Andrew Mills' address on Law Design & Practice Group and ATO’s vision.
Jenny Wong explains why we need to talk about Australian Federation reform.
Maria Lui and John Boyagi highlight the importance of maintaining financial records under tax and corporations law.
Michael Wall discusses the Government’s recently announced Action Plan to increase competitiveness in the Australian economy.
Grant Wardell-Johnson's tribute to Edward Gough Whitlam.
Caroline Hickson discusses the complexities associated with managing host country reporting and taxation of employee share schemes.
James Edwards outlines the eligibility criteria for R&D activities conducted for a foreign entity under the R&D Tax Incentive regime.
Jenny Wong highlights the release of the Government's Innovation Agenda and paradigm shift towards informed policy conversation prior to action.
Belinda Marschke and Hayley Lock discusses how sending employees on an international assignment triggers a multitude of tax considerations.
Ben Travers comments in regards to the Industry Innovation and Competitiveness Agenda and the employee share scheme reforms.
David Sofra's insights into the Victorian election announcement providing significant incentives to employers.
Catherine Pollard extrapolates the intricacies of the Timor-Leste tax regime.
Bernard Finnegan speaks about the introduction of member-directed investment products, in the form of a direct investment option (DIO).
Jenny Wong provides a concise analysis of the key messages from the ATO's speech on G20 Deliverables.
Gareth Newport looks into the information age and technical advancements in computing hardware and software.
John Salvaris examines the accounting values for thin capitalisation purposes and the application of section 820-690.
Belinda and Hayley debunk the underlying complexities involved with short-term business travellers
Scott Olding discusses the R&D Tax Incentive for businesses with an aggregated assessable income greater than AUD $20 billion.
Peter Murray deciphers the critical elements of a freedom of information request during a dispute.
Anthony Petrilli and Quang Doan disseminate the R&D application process for a desirable outcome.
Anthony Seve provides key insights on the OECD's deliverable on transfer pricing intangibles.
Geoffrey Yiu provides a high level synopsis of his presentation at a TTI M&A event.
Tony Mulveney looks at the OECD's focus on substantial activity and transparency to counter harmful tax practices.
Paul Sorrell and Rohan Murugasu applaud the OECD's focus on addressing the tax challenges of the digital economy in a holistic way.
Lani van Ooy shares some recent insights into ASIC's approach to tax effect accounting balances reported in an entity's financial statement.
Grant Wardell-Johnson looks at the progressive timeline of tax treaty developments across different nations and OECD treaty report recommendations.
Jenny Wong examines the OECD's recommendations to address tax treaty abuse.
Damian Preshaw takes a close look at the OECD's BEPS Action Plan release on transfer pricing documentation.
Amanda Leong explores the possible impacts of the Inspector General of Taxation's forward work programme.
Jacqui Tucker outlines the principal ground on which taxpayers are challenged in respect of the definition of 'residence' in Australia.
Michael Wall summarises the government's report on the Integrity Review of the Subclass 457 Visa Program and its 22 recommendations.
Neil Lamb speculates on how proposed changes to the Corporations Act will affect the ATO's approach to capital management
Michelle Bennett shows how buyers can minimise risks and reap the profits they are hoping for by properly conducting their due diligence.
Julian Humphrey and Vanessa Yung consider some of the potential tax risks and pitfalls involved in share buybacks
Kristina Kipper outlines the eligibility requirements to access grant funding for the manufacturing transition programme and growth fund.
Damian Ryan analyses the implications of the SGC schedule amendments contained in the MRRT Repeal Act 2014.
Tony O'Reilly explains the rationale behind Standard Business Reporting, designed to improve interaction between government and business.
Ross Stephens weighs up the pros and cons for super funds regarding the Telstra share buyback.
Birgitte Hassett outlines some of the easily overlooked tricks and traps in the tax consolidation rules.
Angus Wilson outlines the implications of the proposed changes to the foreign dividend rules.
Peter Murray elucidates the ATO's approach to debt recovery when tax disputes arise.
Michael Smith disseminates a Public Officer's obligations when lodging an Australian corporate tax return with an international dealings schedule.
Mark Prentice lays out lessons from a recent AAT decision on keeping good records of R&D activity to protect your access to the R&D tax incentive.
Matthew Popham unveils key insights to maximise the value of trading stock for effective tax cash flow management.
John Bardsley advises financial institutions to consider whether they are getting the full value of the offshore banking unit (OBU) concessions.
Paul Sorrell examines the complex rules and concepts surrounding end to end cloud computing transactions.
Owen Coyle reveals how the ATO's information sharing activity can start a cascade of audits for taxpayers.
Julian Humphrey looks at the new guidance from the ATO on the tax treatment of Bitcoin.
Adam Gibbs analyses a recent Federal Court decision that could have an effect on the taxation treatment of services.
Keith Polkinghorne discusses the still unsettled GST treatment of Bitcoin transactions in Australia, and the potential tax risks.
Craig Yaxley explores capital expenditures under project pool provisions in light of the recent surge of M&A activity.
Jeremy Capes analyses the arguments regarding arm’s length transactions in a forthcoming Federal Court case that could have far-reaching effects.
Brendon Lamers advocates for early consideration of the tax implications of transactions, to prevent tax headaches later on.
Catherine Dean clarifies the difference between making an objection and requesting an amendment, when tax return errors arise.
Mathew Herring explains what the R&D Tax Incentive Scheme’s focus on ‘core’ and ‘supporting’ R&D activities means for taxpayers.
Grant Wardell-Johnson shares insights on BEPS and developing countries gleaned from a seminar with Brazilian BEPS expert, Professor Flavio Rubinstein.
Damian Ryan considers the cost of tax concessions in superannuation policy.
Dermot Gaffney reveals some results of the GST Refund Survey that may be interesting to taxpayers expanding into new markets.
Carlo Franchina identifies some potential focus areas to consider when conducting your fixed asset register health check.
Leonie Ferretter hails the imminent introduction of the Australian Customs Trusted Trader Program.
James Macky examines the logic of recent changes to deductible liability for tax consolidated groups.
Jonathan Turner highlights opportunities for arbitrage of R&D incentives across different jurisdictions.
Michael McAuliffe tallies up the effects of the carbon price repeal on fuel tax credits.
Scott Farrell outlines some issues to consider regarding the recent changes to thin capitalisation rules.
James Gordon reflects on the emerging trend of including tax in the internal audit
Rod Henderson and Jenny Wong look at Australia's current tax treaties with Asia, and ask, is it time for an update?
Alia Lum looks into the possible future for retirement products, in light of the recent FSI interim report and Treasury discussion paper.
Trevor Pascall alerts resource companies to a potentially nasty surprise regarding liability for long-service leave levies.
Tony Mulveney outlines some tax considerations for investors in Australia’s booming property market.
Alun Richards points out the irony in the continuing lack of guidance from the ATO on the transfer pricing changes that have just come into effect.
Cullen Smythe debunks the myth that stamp duty is not owed on transferral of a debt.
Kate Law reminds taxpayers involved in disputes to consider whether GST is payable on the settlement sum.
Tim Lynch and Kristen McIver share some recent experiences with TSAs, and the practical difficulties they encountered in achieving a clear exit.
Jenny Wong deconstructs the Senate composition and provides key insight on a political party's stance across various measures.
Noeleen Robertson untangles some of the complicated factors to consider in determining Australian tax residency.
Ramanie Naidoo advises companies keen to access the R&D tax incentive to consider whether they are the major benefactors of the R&D activities.
Deborah Jenkins counsels GST taxpayers to prepare for errors, and be ready to effectively recover from them.
Matt Birrell reminisces about some of the key tax provisions of the 90s.
Alison Marshall warns taxpayers eligible for the deferred GST scheme to stay up-to-date on their tax obligations, or risk losing out.
Connie Van Werkum laments the lack of movement towards reform of Australia’s Controlled Foreign Company rules.
Julian Humphrey reviews the ATO’s recent Administrative Solution to some of the problems created by the end of LIBOR.
Paul Abela highlights some potential consequences of mismatches between the treatment of goodwill assets in tax, accounting, and commercial domains.
Tim Sandow raises some important issues regarding how the essential nature of business costs affects their tax treatment.
Michael Charles demonstrates how retailers can make tax compliance easier by obtaining tax advice in the planning stages of customer engagement.
Jenny Clarke and Jenny Wong unveil the implications for financial institutions if a CRS is implemented in Australia.
Helen Gilfedder deconstructs TD 2014/15 with respect to design expenditure incurred as part of an R&D project
David Marschke discusses the continuing uncertainty surrounding the defining characteristics of a fixed trust
Emma Crause observes an increased level of scrutiny by the FIRB on the taxation consequences of foreign investment proposals.
Martin Wiesinger considers how some recent court decisions could affect the definition of financing arrangements under Australia’s debt/equity regime.
Praneel Nand outlines some of the key tax issues to be considered regarding unincorporated joint venture arrangements.
Matthew Stutsel contemplates the abolition of the marketable securities, mortgage, and business assets duties promised in the NSW Budget.
Stephen Murphy notes the ATO's recent confirmation of the tax treatment of foreign pension funds seeking to access MIT provisions.
Natalie Raju ponders the fate of the bank deposit levy, one of the announced but unenacted measures that is still unresolved.
Peter Murray praises the utility of good contemporaneous documentation for supporting a taxpayer’s position in a dispute with the ATO.
Nicholas Blunt explains how the Asset Recycling Initiative, announced in the 2014 Budget, will work.
Steven Economides contrasts Australia's handling of collective investment vehicles with principles advanced by the OECD.
Grant Wardell-Johnson congratulates Jeremy Hirschhorn and Kirsten Fish on their upcoming new roles with the ATO as Chief and Deputy Chief Tax Counsel.
Craig Yaxley analyses the likely implications of the draft legislation limiting deductibility of expenditure on mining rights and information.
Daniel Hodgson anticipates the end of the financial year, by outlining some important employment tax issues to consider.
Tony Gorgas explains how a value chain management approach can assist multinational enterprises in adapting and engaging with the digital economy.
Jenny Wong examines the ATO's recent thinking on the requirements for financial reports within the TOFA regime.
Glenn Jackson highlights KPMG's new solution to help ease the pressure of statutory reporting season.
Lisa Smith looks into the likely effects for business of the Government’s proposed indexation of fuel excise.
Michelle Zucker examines the opportunities for businesses arising from the grant funding changes in the Federal Budget.
Rod Henderson eulogises the MRRT, ahead of its seemingly inevitable demise.
Jenny Wong alerts taxpayers to the new status quo – the need to keep abreast of frequent changes to taxation of consolidated groups.
Jeremy Geale observes a recent spate of ATO notices requiring non-residents to provide security for future tax debts, under certain circumstances.
Gary Veale lays out the case for tax specialists as innovation resources.
Nick Kallinikios suggests, in light of the recent Budget, that the Government consider an increase to the rate and scope of the GST.
Alison Young analyses the implications for taxpayers of the recent ED of legislation regarding changes to non-portfolio dividend exemption rules.
Kristina Kipper explores ways companies can utilise productivity project funding through the ERF
Peter Oliver carefully examines the implications of a corporate tax rate reduction.
Abbey Pearce points out some surprising implications for super funds of the recent draft ruling TR 2014/D2, regarding foreign income tax offsets.
Matthew Stutsel weighs the question: "which state is the best for business from a state tax perspective?"
Grant Wardell-Johnson summarises the implications for business of the 2014 Federal Budget.
Rosheen Garnon describes KPMG's reaction to the 2014 Federal Budget.
David Linke discusses the changes to the Corporate Tax Rate in the Federal Budget.
Paul Foxlee looks at the infrastructure implications of the Federal Budget.
Justin Ward examines tax provisions that help maintain the essential GST symmetry for taxpayers.
Michael Hiller explores the impact of the Government’s introduction of a contestability framework.
David Gelb reacts to the R&D funding cut in the 2014 Federal Budget.
Grant Wardell-Johnson provides a summary of his experiences at the 2014 G20 International Tax Symposium in Tokyo.
Mark Poole explores a recent Federal Court decision on the concept of ‘absolute entitlement’ to a trust, and what that could mean for taxpayers.
Saminda Fernando provides an update on developments in the Asia Pacific Funds Passport initiative, including the recent consultation paper.
Anthony Petrilli calls attention to the little known eligibility of National Tax Equivalent Regime entities for the R&D tax incentive.
Graem McClelland analyses a recent government options paper on coastal trading, which contains some key tax reforms affecting shipping.
Stuart Dall shines a light on a recent BEPS discussion paper from the Japanese government, which could impact Australian and Japanese businesses.
James Edwards analyses what taxpayers claiming R&D incentives could learn from the recent AAT decision in the Tier Toys case.
Leonie Ferretter explains how proper consideration of Australia's Free Trade Agreements could have customs duty benefits for some taxpayers.
Grant Wardell-Johnson comments on the change in the temperature of rhetoric from the government regarding the forthcoming budget.
Sarah Dunn looks at the Commissioner’s recent reassurance to taxpayers that the ATO will not often seek to apply laws retrospectively.
Grant Wardell-Johnson examines BoT's three model approaches and proposed new value transfer model in reforming Division 7A.
Peter Mallyon highlights the key elements contained within the BoT's discussion paper on debt/equity provisions.
Bernard Finnegan deciphers TD 2014/D7 with respect to the segregation approach for maintaining exempt status of relevant bank accounts.
Sean Wright discusses the two new Draft Rulings which provide the Commissioner’s view on the application of the reconstruction provisions.
Ben Opie advises non-resident taxpayers on how to engage with the ATO regarding the Australian tax implications of their activities.
John Salvaris talks to a fellow traveller about the benefits of developing a clear tax risk management strategy for their organisation.
Tony O'Reilly explains the ATO's Tax Agent lodgement requirements, and how KPMG is ensuring that our clients meet them.
John Bardsley highlights some issues to consider regarding employee payments following mergers and acquisitions.
Bill Sfikas discusses the mining and exploration rights as depreciating assets under a number of transitional provisions.
John Irwin highlights the challenges and advantages of functional currency rules in preparing dual-ledger financial reports in a non-AUD currency.
Catherine Pollard highlights the increased compliance and substantiation obligations currently facing PRRT taxpayers.
William Arudsothy advises taxpayers to ensure their stamp duty valuations are worth the money.
Gareth Newport provides an update on recent important developments regarding the R&D Tax Incentive.
Craig Yaxley distils the main features of the government’s Exploration Development Incentive discussion paper.
Matthew Popham elucidates some of the complications that can arise for TOFA taxpayers using the default methods.
Mardi Heinrich enumerates the top 5 issues FBT issues for taxpayers to consider as FBT deadlines approach.
Damian Preshaw looks at the increasing disclosure and compliance burden facing multinational companies in relation to country-by-country reporting.
Angus Wilson examines the Productivity Commission’s draft report on Public Infrastructure, identifying some implications for Australian tax policy.
Rod Henderson lays down 7 practical tax tips for organisations in the resources sector to consider during acquisition planning.
Neil Lamb considers the government’s proposed changes to the tax treatment of MEC groups.
Brad Ivens reflects on recent discussion over off-market share buybacks.
Stephen Gottlieb counsels taxpayers who’ve missed the deadline for lodging an amended assessment request that it may not be too late.
Ben Travers looks into some implications of the ATO’s recent draft ruling on employee remuneration trusts.
Louise Lovering observes the attempts of industry groups to position themselves as worthy of tailored tax incentives ahead of the May Federal Budget.
Geoffrey Yiu looks at the government’s recent announcement of changes to the diminishing value depreciation rate for tax consolidated groups.
Dermott Gaffney reveals some disturbing possibilities of the BEPS debate for cross-border indirect tax compliance.
Nick Drizen describes some practical steps that affected taxpayers can take now to prepare for the new transfer pricing self-assessment regime
Jenny Wong highlights the top seven ways to reform the thin capitalisation arm's length debt test.
Carlo Franchina reveals the potentially significant impact that PRRT can have on the value of petroleum projects, and how non-tax teams can help.
Simon Thorp exhorts taxpayers involved in cross border transactions to carefully investigate the specific implications of relevant international DTAs.
Kate Law extols the virtues of GST optimisation in managing your business’s cash flow.
Phil Renshaw summarises a recent court decision regarding when a partnership is deemed to be carrying on an enterprise for GST purposes.
Keith Polkinghorne warns taxpayers that incorrect GST treatment might not be refundable, under proposed legislation.
Damian Ryan looks at the ATO’s recent focus on the tax treatment of expenses paid by super funds to regulators and administrators.
Matthew Herring examines the R&D Tax Incentive integrity rule regarding expenditure not at risk.
Brendon Lamers questions whether Australia’s tax policy settings are right for encouraging necessary infrastructure investment.
Adam Gibbs reconsiders the properties of a financing arrangement under the debt-equity rules, in light of a surprising recent Federal Court decision.
Tony Mulveney highlights the government’s recent decision to pull back on codifying the sovereign immunity exemption.
Trevor Pascall warns taxpayers with a PRRT liability of the looming deadline for lodging returns.
Paul Sorrell outlines the challenges in establishing when technology related payments are ‘royalties’, subject to withholding tax.
Cullen Smythe lays out the differing rules covering insurance duty in Australian states and territories.
Alex Patrick identifies four key principles to consider when a tax dispute arises.
Spencer Reynolds debunks the rumours of the demise of global mobility.
James Macky thanks the High Court for the recent reminder on the importance of reading the text of a law, and not relying on explanatory materials.
David Drummond reviews the changing landscape of global tax transparency.
Michelle Bennett imagines what the movie montage soundtrack of your organisation co-ordinating its tax compliance activity would sound like.
Matt Birrell outlines the dilemma for investors arising from the delayed MIT and Division 6C revisions.
Jeremy Hirschhorn examines international approaches to BEPS, in light of the Dutch Supreme Court’s recent decision on Australian RPS.
Scott Olding clarifies the new opportunities for Australian R&D activities by foreign companies to access the R&D Tax Incentive.
Julian Humphrey and Jeremy Geale reminds corporate taxpayers to regularly assess their tax sharing agreements.
Paul Abela laments the lack of consistency in the treatment of beneficial ownership across the global tax treaty network.
Michael Charles contemplates how the recent Part IVA changes could make assertions of commerciality a problematic defence.
Priscilla Tang explains the recent changes to the 50 percent CGT discount, removing foreign and temporary tax residents from eligibility.
Daniela Chiew raises some issues for corporate taxpayers to consider when selecting a method of calculating monthly PAYG instalments.
Alan Garcia looks into the possible implications of an ATO draft determination regarding design expenditure within R&D projects.
Tim Lynch encourages Australian multinational groups to re-examine their funding structures.
Sean Wright outlines the likely disposition of the ATO towards certain kinds of market support payments.
Peter Murray weighs some of the advantages and pitfalls in the ATO’s Independent Review process for resolving tax disputes.
Ross Stephens counsels superannuation funds to take care in applying unit pricing procedures.
Jenny Wong outlines two proposed goals to guide policy regarding Australia's tax system.
Mardi Heinrich encourages taxpayers to ensure their reporting of cross-border employment income is correct, in light of the ATO’s focus in this area.
Keat Kwan advises companies considering a share capital reduction to look at the potential implications for dividend payment.
Tim Sandow investigates recent changes in the tax treatment of non-cash consideration in mining exploration transactions.
Nicholas Blunt explains how upgrades to plant and equipment assets could affect how tax depreciation rates should be calculated.
Jenny Wong discusses the attributes and approaches of an effective tax policy maker.
Mark Prentice explores the impact of the government’s changes to the R&D tax incentive for business.
Jacqui Tucker and Jodi Schmerl alert taxpayers to the increasingly prevalence of payroll tax reviews from the state revenue offices.
Julian Humphrey reviews the ATO’s new draft determination on dividend washing, and what it could mean for investors.
Jenny Wong predicts the hot topics in Australia tax policy we can look forward to in 2014.
Grant Wardell-Johnson reflects on the history of Federal-State co-operation on income tax, in light of the current Commission of Audit on the subject.
Grant Wardell-Johnson welcomes the appointment of Andrew Mills to the role of ATO Second Commissioner of Taxation.
Matthew Stutsel explains what the removal of the ‘going concern’ GST exemption could mean for business.
Alison Marshall cautions global businesses to consider potential GST liability, before volunteering information to the ATO.
Grant Wardell-Johnson compares MYEFO to PEFO, and the Coalition’s election policy costings.
Helen Gilfedder examines the rules for claiming R&D expenditure of a contractor, in light of a recent decision of the AAT.
Anthony Seve highlights issues associated with an ISAPS review and how to best navigate the complex and high value cross-border transactions.
Minh Dao sketches out the circumstances in which your financing vehicle may be exempt from thin capitalisation.
Stuart Dall examines Japanese Prime Minister Shinzo Abe’s plan to kick-start Japan’s economy.
Jacqui Hardwick and Roseanne Ross make the case for regular data analytics projects to proactively monitor GST compliance.
Matthew Stutsel calls for a re-examination of the estate tax.
Lisa Smith encourages taxpayers to explore ways they can lighten the load of indirect tax compliance costs
Ross Stephens examines the implications of the draft taxation ruling TR 2013/D7 for super funds.
Alison Young counsels companies to be mindful of announced tax measures when preparing half year tax calculations.
Mark Woodward advises taxpayers to consider mitigating the risks of related party financing arrangements with an APA.
Graem McClelland provides key insights into the BoT recommendations on changes to the Australian income tax consolidation regime.
Rosheen Garnon talks about hosting a roundtable meeting with the EU Tax Commissioner on the OECD’s BEPS Action Plan.
Kristina Kipper discusses a recent AAT decision highlighting the ATO’s focus on the validity of expenditure in R&D claims.
Daniel Hodgson lays out the potential risks of a globally mobile workforce, and how best to minimise them.
David Drummond, National Leader of Tax Management Consulting talks about the 'how' not just the 'what' and the 'where' of tax management.
Jane Crisp warns taxpayers of potential negative duty implications of contingent consideration arrangements.
Peter Oliver extols the potential benefits of Standard Business Reporting for streamlining tax reporting.
Alia Lum warns taxpayers that expected benefits from TOFA elective methods may not be available.
Grant Wardell-Johnson speculates on the potential impact of the Murray Inquiry on Australia’s tax reform debate.
Kurt Burrows counsels managers of fixed asset registers to carefully document capital expenditure positions.
David Linke and Grant Wardell-Johnson discuss why the tax reform debate is critical to the future prosperity of the Australian economy.
Jenny Wong enumerates the 5 most important recent developments in the base erosion and profit shifting debate.
Jeremy Capes anticipates what the ATO's shift in nomenclature from ‘transfer pricing’ to ‘profit shifting’ could mean for taxpayers.
James Edwards outlines some issues that companies should be mindful of when compiling their R&D Tax Incentive claims.
Paul Van Bergen debunks the common myth that it is not worth claiming the R&D tax incentive on projects with grant funding, due to clawback.
Leonie Ferretter elucidates the interaction between customs valuation and transfer pricing, and risks and opportunities that can arise for taxpayers.
Saminda Fernando explains the Asian Regions Funds Passport initiative, and its potential benefits for the Australian fund management industry.
Scott Farrell suggests some measures that could be implemented to support the government’s desire for more foreign investment in Australia.
Jenny Wong discusses the proposed repeal of the MRRT, and possible barriers to its passing.
Nick Kallinikios discusses the Commissioner’s recent determination that certain fees do not constitute consideration for a supply, for GST purposes.
Jenny Clarke revisits the Johnson Report’s recommendations on withholding tax, in light of the new government’s election policies.
Sheena Kay identifies taxation rules that could deter superannuation funds from investing in infrastructure.
Rod Henderson and State Shi outline how the implementation of the Government’s tax reform agenda could influence foreign investment in Australia.
Con Tragakis raises some important questions for business owners to consider regarding their vision for their business in the long term.
Jenny Wong distils TOFA into the top three issues currently on the ATO’s radar.
Dermot Gaffney warns taxpayers of a recent ATO review that indicates the ATO’s thinking on input tax estimation tools may be an unpleasant surprise.
Andy Russell outlines the proposed changes to the fuel tax credit in the Government’s carbon pricing repeal draft legislation.
Ben Travers warns businesses to monitor relationships with individual contractors, in light of the ATO’s continued compliance focus in this area.
Jenny Wong enumerates the most important tax issues currently undergoing consultation.
Kate Law draws attention to the risks of ambiguously drafted GST clauses, as demonstrated in a recent decision of the Victorian Supreme Court.
Trevor Pascall lays out a potential remedy for taxpayers who feel the ATO has overstepped their bounds in a taxation dispute.
Matthew Popham concisely identifies the tax implications in leasing equipment from overseas entities.
Adam Gibbs explores the intricacies of Div 6C trusts through the recent decision handed down in BERT Pty Ltd case.
Ben Opie outlines the tax compliance considerations that Petroleum Resource Rent Tax taxpayers should address in preparing to meet their obligations.
Gary Veale unveils his seven habits for successful grant funding to enable further business growth and prosperity.
Jonathan Turner explains why strong documentation of R&D activities is key to sustaining R&D tax claims against regulatory scrutiny.
Glenn Jackson sketches out the common tax compliance challenges facing multinational organisations from across the globe.
Carlo Franchina illuminates the ATO’s contradictory position on the definition of ‘exploration’ for PRRT and income tax purposes.
Jenny Wong speculates on the implications for the Government of the interesting cast of characters in the new Senate that commences in July 2014.
Peter Mallyon explains why the Federal Court is considering what 'just before the joining time' means, and how the decision could affect taxpayers.
Tony O’Reilly extols the virtues of thoughtfully deploying technology to efficiently manage tax reporting and compliance obligations.
Angus Wilson looks at commercial debt forgiveness rules in relation to infrastructure transactions, and how any negative effects might be mitigated.
Justin Ward re-examines the received wisdom on GST, in light of the Full Federal Court's decision in the AP Group Limited case.
Phil Renshaw examines the factors influencing the handling of input tax credits for supply incorrectly treated as taxable by the supplier.
Cullen Smythe warns taxpayers of some confusing traps in state tax obligations that could leave them with unexpected liabilities.
Connie van Werkum weighs the pros and cons of electing to treat investment in a foreign hybrid entity as a partnership for Australian tax purposes.
Brendon Lamers highlights the importance for taxpayers of proper application of the arm’s length test.
Damian Preshaw explores the Transfer Pricing implications of the OECD’s Action Plan on Base Erosion and Profit Shifting.
Catherine Pollard outlines the taxation framework for taxpayers operating the the Joint Petroleum Development Area in the Timor Sea.
Anthony Petrilli explains why taxpayers should prepare to answer the question: who are these R&D activities for?
Maria Lui explains how good record keeping practices can help taxpayers adequately respond to future tax controversies.
Helen Gilfedder contemplates possible developments in R&D tax support under the new Coalition Government.
Bernard Finnegan examines the disclosure requirements for superannuation funds investing in unit trusts or other pooled vehicles.
Massimo Gozzo illuminates some likely effects of proposed changes to the thin capitalisation rules, and how revaluation of assets may help.
Simon Thorp investigates the nebulous status of announced changes to the taxation treatment of earn outs.
Matthew Stutsel observes the recent efforts of the state revenue authorities to boost their cashflow through increased compliance activities.
Alison Young prescribes care and vigilance for taxpayers claiming tax losses.
Bill Sfikas examines some of the Australian tax issues that arise from the use of cross border overriding royalty interests.
Grant Wardell-Johnson looks at one of the challenges facing the incoming government on the international scene – Base Erosion and Profit Shifting.
Mark Woodward encourages taxpayers to take care in documenting their debt arrangements, in light of the recent transfer pricing changes.
John Bardsley outlines how taxpayers can prepare for the thin capitalisation changes commencing on 1 July 2014.
Dana Fleming shows super funds how to ask the crucial questions that will help them manage tax risk.
Jeremy Yap discusses Division 7A, and the risks for large corporate groups of failing to consider its effects.
Tony Mulveney advocates reform of the tax treatment of collective investment vehicles in order to attract foreign investors to Australian projects.
Neil Lamb cautions taxpayers acquiring intangible assets, such as rights to future income, to think carefully about the transaction structure.
Minh Dao discusses the factors determining the correct withholding tax rate for managed investment trusts.
Jeremy Geale explains how Indirect Tax Sharing Agreements can assist corporate groups to manage the risks of GST groupings.
Graem McClelland discusses some of the key benefits and challenges of Multiple Entry Consolidated Groups, and why companies might choose to form them.
Nicholas Blunt explores the complexities in undertaking a Division 58 calculation under the Income Tax Assessment Act 1997.
John Salvaris discusses the provisions in Division 15 under Income Tax Assessment Act 1936.
Tim Sandow analyses the implications for multinational businesses following the proposed thin capitalisation changes announced in the 2013 Budget.
Steven Economides examines Canada's recent consultation paper on treaty shopping.
Keith Polkinghorne provides key insights into lodging July 2013 business activity statements following the recent changes to fuel tax credit rates.
Mark Poole explains why accurate record keeping is crucial for taxpayers managing ATO reviews.
David Bond counsels multinationals in Australia to examine how their transactions may appear in the light of newly enacted transfer pricing rules.
Justin Ward anticipates some changes to GST rules as governments continue to grapple with the challenges of taxing the digital economy.
Stuart Dall analyses the implications of the Government's recent changes to Part IVA.
Jodi Schmerl examines the government's recent efforts to stamp out some widely used tax concessions.
Matthew Herring denotes depreciating assets and provides clarity in which they operate under tax law.
Alan Garcia highlights AusIndustry's three R&D guidance papers key areas and provides insight on navigating the R&D tax requirements.
James Macky examines the High Court's decision in Fortescue v Commonwealth, rejecting the plaintiff's claims that the MRRT is discriminatory.
Peter Murray outlines possible defences against the Government's announced crackdown on corporate interest deductions.
Michael Charles discusses the treatment of transactions in instances where a transaction is deemed to be something other than its legal form.
Paul Abela talks about the taxation of 'land-rich' investments in China under double taxation agreements.
Dermot Gaffney discusses the ATO's GST Compliance Program for 2013-14, which focuses on the integrity of business systems and processes.
Geoffrey Yiu explains the asset cost setting process with regard to Tax consolidation
Nick Kallinikios explores the implications for suppliers of disability supports of the new GST status rules under the NDIS.
Craig Yaxley explains the tax credit proposed by industry stakeholders to stimulate mineral exploration investment in Australia.
William Arudsothy examines the differing implications of farm in arrangements for mining projects in different states.
Jenny Wong examines the proposed new withholding tax regime for foreign residents disposing of Australian property interests
Paul Van Bergen discusses the compliance focus of the ATO and AusIndustry with regard to R&D Tax Incentives.
Saminda Fernando outlines the implications of the new tax loss incentive for designated infrastructure projects.
Jeremy Hirschhorn provides an analysis of the OECD Action Plan on Base Erosion and Profit Shifting, and its implications for Australian companies.
Matt Birrell analyses the differences and compliance conflict between foreign trusts and foreign funds.
Daniela Chiew outlines the ATO's planned compliance focus for 2013-14 in regard to large and multinational businesses.
Lisa Smith analyses the potential refunds for any taxpayer operating heavy vehicles with auxiliary functions.
Peter Oliver assesses the extent of the revenue-saving measures announced in the Federal Budget 2013 driving international business offshore.
Michelle Bennett concisely discusses the tribulations associated with GST refund claims for businesses.
David Drummond analyses disclosure implications on large corporations' tax returns following recent tax transparency measures.
Lani van-Ooy examines the practical tax effects of the new R&D tax incentive regime.
Brahma Sharma explores the opportunities and challenges associated with the implementation of ASEAN Economic Community in strategic planning.
Kurt Burrows draws attention to some recent legislative and judicial developments that will impact the taxation of resource companies.
Jenny Wong provides a firsthand comparative analysis of Section 25-90 from its consultation period in 2001 to its repeal effective from 1 July 2014.
Michael Wall concisely summarises the significant changes to the subclass 457 visa program.
Ross Stephens explains some cash flow management implications of the new requirement for monthly PAYG instalments for superannuation funds.
Jacqui Tucker examines the recent changes to the portability of retirement savings between Australia and New Zealand.
Alison Marshall discusses the apparent limitations on the circumstances in which taxpayers can obtain a GST refund.
Our Tax Team assists with corporate tax, transfer pricing, indirect tax, international executive services, R&D incentives, superannuation and more.
KPMG's review of the major implications arising from the 2014 Federal Budget.
As the tax reform debate increases, KPMG's paper Tax reform for our future success discusses the importance and difficulty of tax reform.
The latest tax legislative developments, Australian Taxation Office releases, new publications and other relevant local and international news.