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  Miscellaneous 2007

International tax McDemott's case

Source: Victoria

Published Date: 12 Oct 2007

 

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With the Court in McDermott finding that ‘you don’t have to be here to be here’ for PE purposes, this paper examines the PE related issues:

  • insights into consequences for internationals PE tax planning including Australia withholding tax implications for Singapore entities and what does the case mean for hiring arrangements and cross border leases
  • implications for PE royalty arrangements governed by other treaties
  • comparison of the Singapore treaty with other treaties and whether the existence of a treaty really matters
  • why the ATO does not want you to have a PE and what action do we expect from the ATO?
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Individual Session

International tax McDermott's case

Author(s): Peter Van Den Broek CTA
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