This paper covers:
- what is the nature of the business and where will activity be undertaken?
- selection of business entities depends on Australian and local laws
- where will the entity have a taxable presence?
- consider the foreign tax regime - interaction with Australian CFC and attribution laws " what will the re-write bring?
- repatriation of foreign profits
- indirect tax impacts (VAT, GST) can be significant and affect business plans
- transfer pricing compliance and planning " how will this be undertaken and what are the risks with Australian and local revenue authorities?