2023 Anti-avoidance

Anti-avoidance measures – Reflections on MAAL, DPT and treaty shopping

Source: New South Wales, Online

Published Date: 22 Jun 2023

 

Australia’s international tax integrity rules continue to evolve with new measures announced in the Government’s October 2022 Budget and the ongoing development of the OECD’s BEPS 2.0 proposals. However, a number of anti-avoidance measures from the original BEPS package are reaching a more mature state as corporate groups have adjusted to their implementation and the ATO has undertaken enforcement activities.

This session reflects on the current state of play across a range of international tax anti-avoidance considerations, including:

  • Learnings from implementation of the MAAL and DPT, how they affected multinational structures and practical experience in dealing with the ATO
  • Views on the application of Part IVA to restructuring activity undertaken in response to these rules; and
  • Effectiveness of the Multilateral Instrument in preventing treaty shopping, including relevant considerations in thinking about the principal purpose test.

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Details

  • Published By: David Lewis
  • Published On:22 Jun 2023
  • Took place at:Amora Hotel Jamison Sydney & Online

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