Incorporating a company offshore seems like the simple answer to ensuring the entity’s foreign-sourced profits are not taxed in Australia. It’s definitely not that simple.
The High Court’s decision in the Bywater Investments case (2016) as well as follow up guidance from the ATO has brought the matter of corporate tax residency sharply into focus.
Taxpayers and advisors need to understand how residency will be determined, as well as the ramifications of being a non-resident for tax purposes. Key matters covered include:
• Tax definition of residency and applying the Bywater case
• ATO views and application – TR 2018/5 and PCG 2018/9
• Implications of residency determinations – taxing rights under DTA; tax consolidation; controlled foreign company rules; disposal of assets; intercompany transactions
Webinar Learning Outcomes:
• How corporate tax residency is determined, particularly for foreign incorporated companies – focussing on management and control
• What the ATO is focussing on in relation to residency
• What the practical implications are when a company is a non-resident
• Corporate tax specialists and advisors will benefit from understanding residency risks within their / their clients’ structures
• Firms of all sizes will benefit from the session
• Whilst the subject matter is advanced, those with limited experience in international matters will benefit from a broad overview of implications arising
Paul Mills has worked in the corporate tax practice at PwC for over 20 years, advising clients on a range of transactions.
For the past seven years, Paul has been responsible for PwC’s national tax technical education program. He is now commencing his own tax advisory business.
You will be provided with:
• PowerPoint presentation slide deck
• Any Supporting documentation
• Webinar Recording to view multiple times for up to 6 months
• An opportunity to ask questions to the presenter
15 August 2019