Global

Details

  • Service: Tax, Global Transfer Pricing Services, Global Compliance Management Services, International Tax
  • Type: Regulatory update
  • Date: 10/22/2013

Australia - Carbon tax repeal, financing arrangements, thin capitalisation  

October 22: Tax issues currently the subject of public consultation with Australia’s government, Board of Taxation, or the Australian Taxation Office (ATO) include:
  • Repeal of the carbon tax and introduction of the Coalition’s emissions reduction fund - The government is consulting on draft legislation to carbon tax and seeking views on the alternative emissions reduction fund, including potential sources of low cost abatement, and on key design features, such as auctions, baselines, and contract arrangements.


  • Repeal of Section 25-90 - The ATO is consulting with industry on what guidance may be needed to apply the law to financing arrangements for Australian multinational groups in the event Section 25-90 is repealed.


  • Debt and equity review - The Board of Taxation conducted consultation to review the current debt/equity rules in Division 974 of the ITAA 97.


  • Thin Capitalisation and arm’s length debt review - The Board of Taxation conducted consultation with various stakeholders to review the thin capitalisation / arm’s length debt test in Division 820 of the ITAA 97, and are exploring ways to make it easier to comply with and administer.


  • Foreign income tax offsets and application to superannuation funds - Technical issues arising from ATOID 2013/14 affecting the superannuation industry in practice is currently being consulted on.


  • Securitisation and thin capitalisation - The ATO withdrew draft TD 2012/D11 on Section 820-39 which would have adversely affected certain securitisation structures in the infrastructure and property industry. Part IVA issues are now being considered by the ATO.

Read an October 2013 report prepared by the KPMG member firm in Australia: Top 6 topical tax issues being consulted on right now




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