International tax & business 2018

The curious reform of foreign source income

Source: The Tax Specialist Journal Article

Published Date: 1 Aug 2018

 

Proposals currently before parliament which change the tax treatment of foreign source income seem to have been largely overlooked. They deserve greater attention because they produce curious and potentially illogical outcomes for many classes of Australian taxpayers. They are the unpublicised consequences of choices made in the design of Australia's anti-hybrid rules, rules which were intended to curb the aggressive tax avoidance practices of multinational enterprises. Instead, they extend to many types of resident taxpayers earning some classes of foreign source income. This article demonstrates how entirely innocuous situations can be affected and how the impacts can be quite unexpected.

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