This presentation provides a general overview of the key international tax considerations for foreign investors contemplating investment into Australia and also Australian corporations expanding their investments overseas. With the Government’s focus on international tax reform, this presentation covers some of the critical Australian taxation areas which need to be addressed in operating in a global market, including:
- basic structuring considerations
- financing considerations (incl. thin cap/TP, withholding taxes and hybrid financing)
- profit flow considerations to provide returns to investors (incl. foreign dividend/branch profits exemptions\
- withholding taxes and CFI)
- future exit from the investment (incl. participation exemption, non-resident CGT and source)
- other (incl. FITOs, CFC rules, treaty overlay).