Structuring cross-border transactions: Part 2
Source: Taxation In Australia Journal Article
Published Date: 1 May 2020
In part 1 of this article, we noted that draft taxation determinations TD 2019/D6 and TD 2019/D7 raise important considerations in
international tax planning and the structuring of Australian investments, with capital gains (whether foreign-sourced or not) attributed to a foreign resident beneficiary of an Australian resident trust being assessable to that beneficiary unless the trust is a fixed trust. In part 2, we delve into the international tax planning issues that the draft taxation determinations create, particularly in relation to Australia's international tax treaty obligations, and the potential impact that these determinations could have in how cross-border investments are structured.
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Details
- Published By: Peter Harper, Renuka Somers CTA
- Published On:1 May 2020
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