On 1 April 2004 the Federal Government introduced into Parliament the New International Tax Arrangements Bill (Participation Exemption and Other Measures) 2004 which resulted in significant changes to Australia's international tax regime.
The 2004 Bill proposed:
- an exemption for all non portfolio dividends
- an exemption for active foreign branch income and capital gains
- a new CGT concession for capital gains arising from disposal of non portfolio interest in active foreign companies
- a new tainted services income rule for Controlled Foreign Companies.
These seminar materials examine in detail the new provisions and the practical implications of:
- the new foreign source income tax exemptions and consequential impacts
- the new CGT concession
- the NITA Bill 2003 (introduced December 2003) - in particular, the Foreign Investment Fund measures.