Maintaining the Momentum of Business TAX REFORM

Save this PDF as:
 WORD  PNG  TXT  JPG

Size: px
Start display at page:

Download "Maintaining the Momentum of Business TAX REFORM"

Transcription

1 Maintaining the Momentum of Business TAX REFORM Senator The Hon Helen Coonan Minister For Revenue & the Assistant Treasurer 1 Maintaining the Momentum of Business Tax Reform

2 The Minister for Revenue and Assistant Treasurer, Senator Helen Coonan, today announced the Government s programme for delivering the next stage of business tax reform measures. these measures affirm the Government s commitment to maintain the momentum of business tax reform and build on the far-reaching reforms that are already in place Senator Coonan said these measures affirm the Government s commitment to maintain the momentum of business tax reform and build on the far-reaching reforms that are already in place. Some of the major measures already working for Australia include the cuts in the company tax rate; halving of the capital gains tax for individual investors; the simplified tax system for small business; the uniform capital allowance system (which also recognised a number of blackhole expenditures); enhanced incentives for research and development; and thin capitalisation rules. The Government has also signed a protocol to amend our double tax agreement with the United States that will benefit many Australian companies operating in the world s biggest economy. More broadly, the review of international tax arrangements will focus on those aspects of taxation that affect the decisions of businesses to locate in Australia and their ability to attract foreign and domestic capital and expand offshore. Senator Coonan emphasised that the aim of the Government s business tax reforms is to deliver a modern, competitive and fair tax system with a reduction in compliance costs facing business, particularly small business. The ultimate aim of tax reform is to promote better living standards and employment opportunities for Australians. Senator Coonan said managing the scope and pace of tax reform is another important consideration in delivering the next phase of business tax reform. The business community s concerns about managing change, while continuing business tax reform, have featured strongly in developing the implementation timetable. A list of business tax reform measures and their date of commencement is at Attachment A. Some specific changes are outlined below. Consolidated Taxation Of Corporate Groups The consolidation measure will involve taxing companies within a wholly-owned corporate group as a single entity, delivering improved commercial flexibility, reducing compliance costs and addressing integrity issues. The measure will commence from 1 July Further details of the consolidation measure was announced on 16 May

3 Tax Relief For Demergers Providing tax relief for demergers will increase efficiency by allowing greater flexibility in structuring businesses, thereby providing an overall benefit to the economy. Tax relief for demergers will be made available where underlying ownership is maintained and the original entity demerges at least 80 per cent of its ownership interest in the demerged entity. Tax relief will be made available to both widely held and non-widely held companies and trusts. Capital gains tax (CGT) relief is to be provided at the member and entity level. An exemption from the existing dividend rules will be provided, subject to an integrity rule. This measure will commence from 1 July Further details of the demerger measure was announced on 6 May Taxation Of Financial Arrangements The remaining reforms to the taxation of financial arrangements (TOFA) will be implemented in stages over the next 2 years (debt/equity reforms came into effect on 1 July 2001). These reforms were recommended by the Review of Business Taxation and have previously received in-principle support from the Government. The TOFA reforms are designed to remove anomalies, distortions and gaps in existing laws, facilitate desirable financial innovation, improve risk management and enhance the efficient operation and competitiveness of Australia s business sector. The next stage of the TOFA reforms will involve revamping the taxation laws relating to foreign currency gains and losses. This will cover the resolution of tensions and uncertainties within the existing law and will include implementing recommendations included in the Review of Business Taxation. Further consultations will be held over coming months (including exposure draft legislation) with a view to introducing legislation in the Spring Sittings. This will be followed by reform of the taxation of commodity (e.g. gold and cotton) hedging. These reforms will remove tax uncertainties and allow more efficient hedging arrangements. The commencement date will be 1 July Further industry consultations will be undertaken to settle the details of the Government s policy approach. The final stage includes implementation of new tax-timing arrangements, including a mark-to-market election, an accruals/ realisation framework, internal hedging rules, disposal rules and synthetic arrangements. The commencement date will be 1 July Maintaining the Momentum of Business Tax Reform

4 The Government has decided not to proceed with the recommendations made by the Review of Business Taxation to introduce measures to tax life insurance policyholders... Removal Of Taxing Point At Conversion Or Exchange Of Certain Financial Instruments Under the current tax law, the point of conversion or exchange of certain financial instruments represents a taxing point for income tax purposes. This taxing point is to be removed from the taxation law and will apply to traditional securities that are issued after 7.30 pm EST 14 May Relevant financial instruments issued before this announcement will continue to be subject to the current tax law. The effect of this announcement will be that an investor who holds a relevant financial instrument through conversion or exchange will not be subject to tax until it is ultimately sold. Furthermore, where the gain or loss on disposal is of a capital nature, the investor will be able to qualify for capital gains treatment for the period before, and after, conversion or exchange. Introduction Of A Withholding Tax Regime For Non-residents Without A Permanent Presence In Australia The Review of Business Taxation recommended the introduction of a uniform withholding tax regime on taxable Australian-source income and gains derived by non-residents. The Government has previously agreed in-principle with this recommendation, to commence from 1 July To minimise the compliance burden on Australian businesses, the Government has decided to proceed with a modified approach to the implementation of this measure, with obligations for withholding to be developed as required for specific industries, and supported by the existing Pay As You Go (PAYG) withholding system. Following further consultations, any new obligations to withhold will be introduced progressively by regulations from 1 July 2003, with enabling legislation to be introduced prior to 1 July Taxation Of Life Insurance Policyholders The Government has decided not to proceed with the recommendations made by the Review of Business Taxation to introduce measures to tax life insurance policyholders like they are shareholders in companies due to concerns about compliance costs. However, the Review of Business Taxation s recommendations affecting special investment products offered by friendly societies will be implemented, with some modification. To ensure that investment income paid by friendly societies is only subject to 4

5 one level of tax, friendly societies will be entitled to a deduction from 1 January 2003 for amounts paid to policyholders relating to income bonds, funeral policies and scholarship plans taken out after 30 November Legislation to introduce these reforms will be developed in consultation with industry. Simplified Imputation System The Simplified Imputation System will commence on 1 July 2002 as previously announced, with legislation scheduled for introduction into Parliament in the Winter sittings. Since release of the earlier exposure draft legislation, the measure has been subject to consultation with representatives of small and large business. Further details of the measure will be announced shortly. Franking Credits For Foreign Dividend Withholding Tax And The Establishment Of Foreign Income Accounts In light of their significant linkages with the central issues identified to date by business for consideration in the review of international tax arrangements, the Government has decided to defer, pending the review, implementation of the measures to provide franking credits for foreign dividend withholding tax and to establish foreign income accounts. Tax Exempt Leasing And Effective Life Depreciation Of Buildings And Structures Although there is broad agreement with the States and private sector on a framework to replace the existing section 51AD and the associated Division 16D provisions, significant boundary and implementation issues remain to be resolved. Further consultation on these issues will be undertaken through the course of and it is expected that legislation will be introduced in the Autumn 2003 sittings. Reform of general leasing rules remains under development. The Government accepted in principle the RBT recommendation that new buildings and structures should be included in the uniform capital allowance system. The Treasurer s press release of 22 March 2001 noted that this issue still required further policy development and consultation. This measure raises a number of extremely difficult practical issues, including separating land value from that of the buildings and structures, and defining the asset unit (a single building or many smaller assets). In light of the need for significant amounts 5 Maintaining the Momentum of Business Tax Reform

6 of further work and competing tax priorities, the measure, if proceeded with, will not commence until at least July The General Value Shifting Regime The general value shifting regime is designed to prevent the manipulation of ordinary tax rules by shifting taxable value between assets by related parties. The general value shifting regime will apply to arrangements and dealings involving entities that are not part of the same consolidated group, but are nevertheless related in some other way. The measure will commence from 1 July 2002 and legislation is scheduled for introduction into Parliament in the Winter sittings. Tax Value Method The Board of Taxation is currently receiving public comments on its prototype legislation for the Tax Value Method (TVM). The Board expects to be able to provide its recommendation by the middle of the year to the Government as to whether and when the TVM should be introduced. Without prejudicing the Board s or the Government s views on whether TVM should proceed, it is clear that any implementation could not occur before July 2005, at the earliest. In the meantime, consideration of reforms to the taxation of rights and any blackhole expenditures will continue to be undertaken on a case-by-case basis. 6

7 Attachment A Timetable For Business Tax Reforms Measure Commencement Date Legislation Introduced Consolidated taxation of corporate groups 1 July 2002 Initial package of legislation to be introduced in Winter 2002 sittings. Remainder of legislation to be introduced in Spring 2002 sittings. The general value shifting regime 1 July 2002 Legislation to be introduced in Winter 2002 sittings. Tax relief for demergers 1 July 2002 Legislation expected to be introduced in Winter 2002 sittings. Taxation of financial arrangements (TOFA) Stage 1: debt/equity borderline Stage 2: foreign currency gains and losses Stage 3: commodity hedges Stage 4: tax-timing rules, disposal rules and synthetic arrangements 1 July 2001 To be decided 1 July July 2004 Legislation enacted. Legislation to be introduced in Spring 2002 sittings. Legislation to be introduced in Winter 2003 sittings. Legislation to be introduced in Winter 2004 sittings. Removal of taxing point at conversion or exchange of financial instruments Introduction of a withholding tax regime for non-residents without a permanent establishment in Australia Taxation of life insurance policyholders From date of announcement Legislation to be introduced in Spring 2002 sittings 1 July 2003 Legislation to be introduced prior to 1 July 2003 Current law to remain unchanged. Measure Commencement Date Legislation Introduced Special investment products offered by friendly societies 1 January 2003 Legislation to be developed in consultation with industry. Simplified imputation system 1 July 2002 Legislation to be introduced in Winter 2002 sittings. Franking credits for foreign dividend withholding tax and the establishment of foreign income accounts To be considered in the review of international taxation arrangements Tax exempt leasing 1 July 2003 Legislation to be introduced in Autumn 2003 sittings. Effective life depreciation of buildings and structures Tax Value Method and other high level rules Taxable leasing and the treatment of partnerships and joint activities Not before July 2005 Not before July 2005 Under further development To be determined. General anti-avoidance rule Date of introduction of legislation To be determined. 7 Maintaining the Momentum of Business Tax Reform

8 8

represents 70 percent of the Federal Government

represents 70 percent of the Federal Government GENERAL TAX ISSUES Income tax represents approximately 70 percent of the total tax revenue of the Australian Federal Government Income tax represents approximately 70 percent of the total tax revenue of

More information

NZ Society of Actuaries. Conference. Wairakei - November 2008 Anthony Merritt

NZ Society of Actuaries. Conference. Wairakei - November 2008 Anthony Merritt LIFE INSURANCE TAX REFORM Life NZ Insurance Society of Actuaries Tax Conference Reform Wairakei NZ Society of Actuaries Conference November 2008 Wairakei - November 2008 Anthony Merritt Policy Advice Anthony

More information

TAX AND SUPERANNUATION LAWS AMENDMENT (2014 MEASURES NO.#) BILL 2014: EXPLORATION DEVELOPMENT INCENTIVE EXPLANATORY MATERIAL

TAX AND SUPERANNUATION LAWS AMENDMENT (2014 MEASURES NO.#) BILL 2014: EXPLORATION DEVELOPMENT INCENTIVE EXPLANATORY MATERIAL TAX AND SUPERANNUATION LAWS AMENDMENT (2014 MEASURES NO.#) BILL 2014: EXPLORATION DEVELOPMENT INCENTIVE EXPLANATORY MATERIAL Table of contents Glossary... 1 Chapter 1 Exploration development incentive...

More information

Company Tax Return Preparation Checklist 2010

Company Tax Return Preparation Checklist 2010 Company Tax Return Preparation Checklist 2010 The following income tax return checklist should be completed in conjunction with the preparation of tax reconciliation return workpapers. The checklist provides

More information

International Accounting Standard 12 Income Taxes. Objective. Scope. Definitions IAS 12

International Accounting Standard 12 Income Taxes. Objective. Scope. Definitions IAS 12 International Accounting Standard 12 Income Taxes Objective The objective of this Standard is to prescribe the accounting treatment for income taxes. The principal issue in accounting for income taxes

More information

to taxation Australian 2005, and The discussions below

to taxation Australian 2005, and The discussions below General Tax Information Relating to Holdings in Cadbury plc and Cadbury Schweppes plc This discussion of Australian, UK and US tax law considerations is intended only as a descriptive summary and does

More information

LIFE INSURANCE COMPANIES

LIFE INSURANCE COMPANIES CONSOLIDATION: LIFE INSURANCE COMPANIES MODIFICATION OF TAX COST SETTING RULES ON LEAVING A CONSOLIDATED GROUP PURPOSE 1. The special tax cost setting rules that apply to life insurance companies that

More information

Chapter BB Buy-backs of shares and non-share equity interests

Chapter BB Buy-backs of shares and non-share equity interests Chapter BB Buy-backs of shares and non-share equity interests Outline of chapter 1.1 Schedule BB to this Bill implements the recommendations of the Board of Taxation to improve the taxation arrangements

More information

Income Taxes STATUTORY BOARD SB-FRS 12 FINANCIAL REPORTING STANDARD

Income Taxes STATUTORY BOARD SB-FRS 12 FINANCIAL REPORTING STANDARD STATUTORY BOARD SB-FRS 12 FINANCIAL REPORTING STANDARD Income Taxes This version of the Statutory Board Financial Reporting Standard does not include amendments that are effective for annual periods beginning

More information

Indian Accounting Standard (Ind AS) 12. Income Taxes

Indian Accounting Standard (Ind AS) 12. Income Taxes Indian Accounting Standard (Ind AS) 12 Contents Income Taxes Paragraphs Objective Scope 1 4 Definitions 5 11 Tax base 7 11 Recognition of current tax liabilities and current tax assets 12 14 Recognition

More information

Sri Lanka Accounting Standard LKAS 12. Income Taxes

Sri Lanka Accounting Standard LKAS 12. Income Taxes Sri Lanka Accounting Standard LKAS 12 Income Taxes CONTENTS paragraphs SRI LANKA ACCOUNTING STANDARD-LKAS 12 INCOME TAXES OBJECTIVE SCOPE 1 4 DEFINITIONS 5 11 Tax base 7 11 RECOGNITION OF CURRENT TAX LIABILITIES

More information

Company tax return 2015

Company tax return 2015 Company tax return 2015 Day Month Year Day Month Year to Or specify period if part year or approved substitute period tes to help you prepare this tax return are in the Company tax return instructions

More information

Hon Dr Michael Cullen Minister of Finance

Hon Dr Michael Cullen Minister of Finance Hon Dr Michael Cullen Minister of Finance Pro-business tax cuts: background information Fairer rules on taxing investment income New rules will make the taxation of income from investment through managed

More information

International Accounting Standard 12 Income Taxes

International Accounting Standard 12 Income Taxes EC staff consolidated version as of 21 June 2012, EN IAS 12 FOR INFORMATION PURPOSES ONLY International Accounting Standard 12 Income Taxes Objective The objective of this Standard is to prescribe the

More information

Australia. An insurer that writes general insurance contracts as defined under AASB4.

Australia. An insurer that writes general insurance contracts as defined under AASB4. Australia International Comparison of Insurance * May 2009 Australia General Insurance Definition Definition of property and casualty insurance company Commercial Accounts/Tax and Regulatory Returns Basis

More information

TAXATION OF INTEREST, DIVIDENDS AND CAPITAL GAINS IN CYPRUS

TAXATION OF INTEREST, DIVIDENDS AND CAPITAL GAINS IN CYPRUS TAXATION OF INTEREST, DIVIDENDS AND CAPITAL GAINS IN CYPRUS LAWS AND DECREES The Income Tax (Amendment) Law of 2005 The Special Contribution for Defence (Amendment) Law of 2004 The Assessment and Collection

More information

AUSTRALIA S NEW FOREX REGIME

AUSTRALIA S NEW FOREX REGIME AUSTRALIA S NEW FOREX REGIME By Stephen Barkoczy * Australia has recently adopted a revolutionary new codified regime for dealing with the taxation treatment of transactions that occur in foreign currency.

More information

The Australian dollar versus the US dollar. Disclaimer. Foreign currency denominated transactions. Example Foreign Exchange Gain

The Australian dollar versus the US dollar. Disclaimer. Foreign currency denominated transactions. Example Foreign Exchange Gain Walter Gianotti and Erin Gordon, ATO 2009 Lost in Translation: Foreign Exchange Gains and Losses Disclaimer: The material in this presentation is published on the basis that the opinions expressed are

More information

Wrap Tax Guide Self Managed Super Fund Part 1

Wrap Tax Guide Self Managed Super Fund Part 1 Wrap Tax Guide Self Managed Super Fund Part 1 Wrap Tax Policy Guide For the year ended 30 June 2015 General Information Part 1 of the Wrap Tax Guide outlines the tax assumptions and policies Wrap Services

More information

NAS 09 NEPAL ACCOUNTING STANDARDS ON INCOME TAXES

NAS 09 NEPAL ACCOUNTING STANDARDS ON INCOME TAXES NAS 09 NEPAL ACCOUNTING STANDARDS ON INCOME TAXES CONTENTS Paragraphs OBJECTIVE SCOPE 1-4 DEFINITIONS 5-11 Tax Base 7-11 RECOGNITION OF CURRENT TAX LIABILITIES AND CURRENT TAX ASSETS 12-14 RECOGNITION

More information

Company tax return instructions 2014

Company tax return instructions 2014 Instructions for companies Company tax return instructions 2014 To help you complete the company tax return for 1 July 2013 30 June 2014 For more information visit ato.gov.au NAT 0669-06.2014 OUR COMMITMENT

More information

Israeli Tax Reform of 2005

Israeli Tax Reform of 2005 Israeli Tax Reform of 2005 The Israeli Parliament approved on July 25, 2005 the proposed income tax reform legislation (the Tax Reform ) pursuant to the recommendations of a committee appointed by the

More information

4.1 General 4.2 Draft taxation determination TD2004/D1

4.1 General 4.2 Draft taxation determination TD2004/D1 4.1 General The following comments: are a general guide to the Australian taxation implications of selling your Shares in the Buy-back; may not apply to you if you buy and sell Shares in the ordinary course

More information

Company tax return instructions 2015

Company tax return instructions 2015 Instructions for companies Company tax return instructions 2015 To help you complete the company tax return for 1 July 2014 30 June 2015 For more information visit ato.gov.au NAT 0669-06.2015 OUR COMMITMENT

More information

As a general rule, Australian dollar amounts in the calculation of a taxpayer s

As a general rule, Australian dollar amounts in the calculation of a taxpayer s FOREIGN CURRENCY GAINS AND LOSSES 1 The Recognition of Foreign Currency Gains and Losses in Australian Income Tax Law GA BARTON * The Australian income tax implications of deriving a foreign currency gain

More information

Company Income Tax and Other Taxes

Company Income Tax and Other Taxes Company Income Tax and Other Taxes Company Taxation Arrangements The company tax rate (also known as the corporate) is 30%. The treatment of business expenditure for the mining and petroleum industries

More information

Australia Tax Alert. Budget 2013-14 targets debt funding by multinationals. Thin capitalization rules. International Tax. 15 May 2013.

Australia Tax Alert. Budget 2013-14 targets debt funding by multinationals. Thin capitalization rules. International Tax. 15 May 2013. International Tax Australia Tax Alert Contacts Peter Madden pmadden@deloitte.com.au Claudio Cimetta ccimetta@deloitte.com.au Vik Khanna vkhanna@deloitte.com.au Alyson Rodi arodi@deloitte.com.au David Watkins

More information

You and your shares 2013

You and your shares 2013 Instructions for shareholders You and your shares 2013 For 1 July 2012 30 June 2013 Covers: n individuals who invest in shares or convertible notes n taxation of dividends from investments n allowable

More information

CYPRUS TAX CONSIDERATIONS

CYPRUS TAX CONSIDERATIONS TAXATION The following summary of material Cyprus, US federal income and United Kingdom tax consequences of ownership of the GDRs is based upon laws, regulations, decrees, rulings, income tax conventions

More information

Simplified Imputation

Simplified Imputation July SA Bi-Monthly Simplified Imputation Helen Waldie Edwards Marshall Helen Waldie 2008 Disclaimer: The material in this presentation is published on the basis that the opinions expressed are not to be

More information

Transition to International Financial Reporting Standards

Transition to International Financial Reporting Standards Transition to International Financial Reporting Standards Topps Tiles Plc In accordance with IFRS 1, First-time adoption of International Financial Reporting Standards ( IFRS ), Topps Tiles Plc, ( Topps

More information

The Advantages of the UK as a Location for a Holding Company. David Gibbs May 2015

The Advantages of the UK as a Location for a Holding Company. David Gibbs May 2015 The Advantages of the UK as a Location for a Holding Company David Gibbs May 2015 The UK is an attractive location to site an international holding company since not only does it offer a relatively stable

More information

ABN 17 006 852 820 PTY LTD (FORMERLY KNOWN AS AQUAMAX PTY LTD) DIRECTORS REPORT FOR THE YEAR ENDED 30 SEPTEMBER 2015

ABN 17 006 852 820 PTY LTD (FORMERLY KNOWN AS AQUAMAX PTY LTD) DIRECTORS REPORT FOR THE YEAR ENDED 30 SEPTEMBER 2015 DIRECTORS REPORT FOR THE YEAR ENDED 30 SEPTEMBER 2015 In accordance with a resolution of the Directors dated 16 December 2015, the Directors of the Company have pleasure in reporting on the Company for

More information

Implementing a Diverted Profits Tax

Implementing a Diverted Profits Tax Implementing a Diverted Profits Tax May 2016 Commonwealth of Australia 2016 ISBN 978-1-925220-92-6 This publication is available for your use under a Creative Commons Attribution 3.0 Australia licence,

More information

Accounting Standard AASB 1020 December 1999. Income Taxes. Issued by the Australian Accounting Standards Board

Accounting Standard AASB 1020 December 1999. Income Taxes. Issued by the Australian Accounting Standards Board Accounting Standard AASB 1020 December 1999 Income Taxes Issued by the Australian Accounting Standards Board Obtaining a Copy of this Accounting Standard Copies of this Standard are available for purchase

More information

You and your shares 2015

You and your shares 2015 Instructions for shareholders You and your shares 2015 For 1 July 2014 30 June 2015 Covers: n individuals who invest in shares or convertible notes n taxation of dividends from investments n allowable

More information

Business Coalition for Tax Reform

Business Coalition for Tax Reform Business Coalition for Tax Reform Tax Value Method Submission to the Board of Taxation 10 May 2002 Table of Contents Executive Summary 2 Section 1. Introduction 4 Section 2. The Business Coalition for

More information

NATIONAL BUDGET 2012/13

NATIONAL BUDGET 2012/13 NATIONAL BUDGET 2012/13 On 22 February 2012 the Finance Minister, Pravin Gordhan delivered his National Budget Speech and announced the tax proposals for the forthcoming year as well as proposals which

More information

TAXATION INFORMATION. Purchases of Ordinary Shares by the Mondi Incentive Schemes Trust Trustees

TAXATION INFORMATION. Purchases of Ordinary Shares by the Mondi Incentive Schemes Trust Trustees TAXATION INFORMATION South African taxation The following is a general summary of the South African tax implications for Ordinary Shares held by South African tax residents included in the Odd-lot Offer,

More information

Hong Kong. Country M&A Team Country Leader ~ Nick Dignan Guy Ellis Rod Houng-Lee Anthony Tong Sandy Fung Greg James Louise Leung Nicholas Lui

Hong Kong. Country M&A Team Country Leader ~ Nick Dignan Guy Ellis Rod Houng-Lee Anthony Tong Sandy Fung Greg James Louise Leung Nicholas Lui Hong Kong Country M&A Team Country Leader ~ Nick Dignan Guy Ellis Rod Houng-Lee Anthony Tong Sandy Fung Greg James Louise Leung Nicholas Lui Mergers & Acquisitions Asian Taxation Guide 2008 Hong Kong March

More information

Global Value Fund Limited A.B.N. 90 168 653 521. Appendix 4E - Preliminary Financial Report for the year ended 30 June 2015

Global Value Fund Limited A.B.N. 90 168 653 521. Appendix 4E - Preliminary Financial Report for the year ended 30 June 2015 A.B.N. 90 168 653 521 Appendix 4E - Preliminary Financial Report for the year ended 30 June 2015 Appendix 4E - Preliminary Financial Report For the year ended 30 June 2015 Preliminary Report This preliminary

More information

G8 Education Limited ABN: 95 123 828 553. Accounting Policies

G8 Education Limited ABN: 95 123 828 553. Accounting Policies G8 Education Limited ABN: 95 123 828 553 Accounting Policies Table of Contents Note 1: Summary of significant accounting policies... 3 (a) Basis of preparation... 3 (b) Principles of consolidation... 3

More information

How Canada Taxes Foreign Income

How Canada Taxes Foreign Income - 1 - How Canada Taxes Foreign Income (Summary) Purpose of the book The purpose of writing this book, entitled How Canada Taxes Foreign Income is particularly for the benefit of foreign tax lawyers, accountants,

More information

New Zealand. Country M&A Team Country Leader ~ Peter Boyce Declan Mordaunt Mike Morgan Eleanor Ward Ian Fay Michelle Redington Ravi Mehta

New Zealand. Country M&A Team Country Leader ~ Peter Boyce Declan Mordaunt Mike Morgan Eleanor Ward Ian Fay Michelle Redington Ravi Mehta New Zealand Country M&A Team Country Leader ~ Peter Boyce Declan Mordaunt Mike Morgan Eleanor Ward Ian Fay Michelle Redington Ravi Mehta Mergers & Acquisitions Asian Taxation Guide 2008 New Zealand March

More information

1.1. The Importance of Superannuation and Life Insurance

1.1. The Importance of Superannuation and Life Insurance 1 CHAPTER 1 - INTRODUCTION 1.1. The Importance of Superannuation and Life Insurance Superannuation funds and life offices have played an important role as vehicles through which people have accumulated

More information

Non-final withholding tax on transactions involving taxable Australian property

Non-final withholding tax on transactions involving taxable Australian property Non-final withholding tax on transactions involving taxable Australian property Discussion Paper October 2014 Commonwealth of Australia 2014 ISBN 978-1-925220-16-2 This publication is available for your

More information

ACCOUNTING ALERT ASSURANCE AND ADVISORY. June 2003 Financial Reporting Update

ACCOUNTING ALERT ASSURANCE AND ADVISORY. June 2003 Financial Reporting Update Tax Accounting Services Case AlertStudies Analysis of the latest accounting developments delivered to you via e-mail Alert # 2003/05 Issued 3 July 2003 June 2003 Financial Reporting Update This Accounting

More information

Appendix 3. The metric

Appendix 3. The metric Appendix 3 A consistent and useful effective tax rate methodology to assess the global tax performance of multinationals in relation to Australian-linked business operations 1 The purpose of this paper

More information

Post implementation review into certain aspects of the consolidation regime. Discussion Paper. boardtaxation. the of. www.taxboard.gov.

Post implementation review into certain aspects of the consolidation regime. Discussion Paper. boardtaxation. the of. www.taxboard.gov. Post implementation review into certain aspects of the consolidation regime Discussion Paper boardtaxation the of www.taxboard.gov.au The Board of Taxation December 2009 Commonwealth of Australia 2009

More information

Accountant s Tax Guide

Accountant s Tax Guide Accountant s Tax Guide For the year ended 30 June 2010 Macquarie Wrap Macquarie Adviser Services Tax policies and general assumptions The purpose of the Accountants Tax Guide (the Guide) is to provide

More information

This paper is a guide as to how the broad principles recommended by the Board of Taxation might operate.

This paper is a guide as to how the broad principles recommended by the Board of Taxation might operate. TREASURY DISCUSSION PAPER TAXATION TREATMENT OF OFF-MARKET SHARE BUYBACKS NOTE TO PARTICIPANTS This paper is a guide as to how the broad principles recommended by the Board of Taxation might operate. INTRODUCTION

More information

Budget 2014 26 February 2014

Budget 2014 26 February 2014 1 Budget 2014 Budget 2014 26 February 2014 The Minister of Finance, Mr Pravin Gordhan, today announced a revised consolidated net tax revenue estimate for 2014/2015 of R997,7 billion and a slightly reduced

More information

GLOBAL GUIDE TO M&A TAX

GLOBAL GUIDE TO M&A TAX Quality tax advice, globally GLOBAL GUIDE TO M&A TAX 2013 EDITION www.taxand.com CYPRUS Cyprus From a Buyer s Perspective 1. What are the main differences among acquisitions made through a share deal versus

More information

TAX LAWS AMENDMENT (TAX INTEGRITY MULTINATIONAL ANTI-AVOIDANCE LAW) BILL 2015 EXPOSURE DRAFT EXPLANATORY MATERIAL

TAX LAWS AMENDMENT (TAX INTEGRITY MULTINATIONAL ANTI-AVOIDANCE LAW) BILL 2015 EXPOSURE DRAFT EXPLANATORY MATERIAL TAX LAWS AMENDMENT (TAX INTEGRITY MULTINATIONAL ANTI-AVOIDANCE LAW) BILL 2015 EXPOSURE DRAFT EXPLANATORY MATERIAL Table of contents Glossary... 1 Tax integrity multinational anti-avoidance law... 3 Glossary

More information

New Zealand. A company to which insurance legislation applies. after 1 January 2007.

New Zealand. A company to which insurance legislation applies. after 1 January 2007. New Zealand International Comparison of Insurance * May 2009 New Zealand General Insurance Definition Definition of property and casualty insurance company Commercial Accounts/Tax and Regulatory Returns

More information

Year-end tax planning toolkit. Year-ending 30 June 2014

Year-end tax planning toolkit. Year-ending 30 June 2014 Year-end tax planning toolkit Year-ending 30 June 2014 June 2014 The contents of this document are for general information only and do not consider your personal circumstances or situation. Furthermore,

More information

Country Tax Guide. www.bakertillyinternational.com

Country Tax Guide. www.bakertillyinternational.com www.bakertillyinternational.com International Tax Contact Moscow Andrey Kirillov T: +7 (495) 783 88 00 a.kirillov@bakertillyrussaudit.ru Corporate Income Taxes Resident companies, defined as those which

More information

Taxation treatment of Exchange Traded Options

Taxation treatment of Exchange Traded Options Taxation treatment of Exchange Traded Options 18 May 2011 Patrick Broughan, Director, Deloitte Touche Tohmatsu Ltd Alison Noble, Account Director, Deloitte Touche Tohmatsu Ltd The views in this document

More information

HKAS 12 Revised May November 2014. Hong Kong Accounting Standard 12. Income Taxes

HKAS 12 Revised May November 2014. Hong Kong Accounting Standard 12. Income Taxes HKAS 12 Revised May November 2014 Hong Kong Accounting Standard 12 Income Taxes HKAS 12 COPYRIGHT Copyright 2014 Hong Kong Institute of Certified Public Accountants This Hong Kong Financial Reporting Standard

More information

Mexico Mergers and acquisitions involving Mexican assets

Mexico Mergers and acquisitions involving Mexican assets p84-88 IM&A - Chevez Rulz 21/03/2013 08:44 Page 84 Mexico Mergers and acquisitions involving Mexican assets by Ricardo Rendon and Layda Carcamo, Chevez, Ruiz, Zamarripa y Cia, S.C. Whenever a corporate

More information

BLACKSTONE ALTERNATIVE INVESTMENT FUNDS PLC. (the Company ) An umbrella fund with segregated liability between sub-funds, and its sub-fund

BLACKSTONE ALTERNATIVE INVESTMENT FUNDS PLC. (the Company ) An umbrella fund with segregated liability between sub-funds, and its sub-fund BLACKSTONE ALTERNATIVE INVESTMENT FUNDS PLC (the Company ) An umbrella fund with segregated liability between sub-funds, and its sub-fund (the Fund ) SUPPLEMENT FOR UNITED KINGDOM INVESTORS This Supplement

More information

Sale and leaseback how it could benefit your business

Sale and leaseback how it could benefit your business COLLIERS INTERNATIONAL WHITE PAPER 2015 Sale and leaseback how it could benefit your business The greatest benefit of a sale and leaseback transaction is the ability for the owner occupier to increase

More information

Tax Brief. 19 March 2010. Consolidating Consolidation. Tax cost setting amount for rights to future income and revenue assets. Rights to future income

Tax Brief. 19 March 2010. Consolidating Consolidation. Tax cost setting amount for rights to future income and revenue assets. Rights to future income Tax Brief 19 March 2010 Consolidating Consolidation The Tax Laws Amendment (2010 Measures No. 1) Bill 2010 ( the Bill ) was introduced into Parliament on 10 February 2010. Schedule 5 of the Bill contains

More information

New Zealand Equivalent to International Accounting Standard 12 Income Taxes (NZ IAS 12)

New Zealand Equivalent to International Accounting Standard 12 Income Taxes (NZ IAS 12) New Zealand Equivalent to International Accounting Standard 12 Income Taxes (NZ IAS 12) Issued November 2004 and incorporates amendments up to and including 31 October 2010 other than consequential amendments

More information

Holding companies in Ireland

Holding companies in Ireland Holding companies in Irel David Lawless Paul Moloney Dillon Eustace, Dublin Irel has long been a destination of choice for holding companies because of its low corporation tax rate of 12.5 percent, participation

More information

USA Taxation. 3.1 Taxation of funds. Taxation of regulated investment companies: income tax

USA Taxation. 3.1 Taxation of funds. Taxation of regulated investment companies: income tax USA Taxation FUNDS AND FUND MANAGEMENT 2010 3.1 Taxation of funds Taxation of regulated investment companies: income tax Investment companies in the United States (US) are structured either as openend

More information

Tax Reform in Brazil and the U.S.

Tax Reform in Brazil and the U.S. Tax Reform in Brazil and the U.S. Devon M. Bodoh Principal in Charge Latin America Markets, Tax KPMG LLP Carlos Eduardo Toro Director KPMG Brazil Agenda Overview of Global Tax Reform Overview Organization

More information

45095 Forex Gains and Losses http://www.ato.gov.au/rba/content.asp?doc=45095

45095 Forex Gains and Losses http://www.ato.gov.au/rba/content.asp?doc=45095 1 45095 Forex Gains and Losses http://www.ato.gov.au/rba/content.asp?doc=45095 Application of foreign currency (forex) rules to 45250 repayment of foreign currency denominated loan http://www.ato.gov.au/rba/content.asp?doc=45250

More information

Profits from Trading in and Developing UK Land

Profits from Trading in and Developing UK Land Profits from Trading in and Developing UK Land 16 March 2016 Technical Note 1 Contents Summary Chapter 1 Chapter 2 Current legislation Details of the new legislation 2 SUMMARY Some property developers

More information

GUIDE TO CAPITAL GAINS TAX 2002 03

GUIDE TO CAPITAL GAINS TAX 2002 03 GUIDE TO CAPITAL GAINS TAX 2002 03 Covers: Individuals who have sold their main residence Individuals with complex capital gains tax obligations Companies, trusts and funds Lodge online with e-tax at www.ato.gov.au

More information

Congress Begins Work on ETI Replacement Legislation (08/01/03)

Congress Begins Work on ETI Replacement Legislation (08/01/03) Congress Begins Work on ETI Replacement Legislation (08/01/03) Prior to the start of a month-long August recess, the House and Senate tax-writing committees began consideration of potential solutions to

More information

A E. 03 The full syllabus operational level continued. The full syllabus operational level F1 A. PRINCIPLES OF BUSINESS TAXATION (25%)

A E. 03 The full syllabus operational level continued. The full syllabus operational level F1 A. PRINCIPLES OF BUSINESS TAXATION (25%) A E B D C 03 continued PAPER F1 FINANCIAL OPERATIONS Syllabus overview The core objectives of Paper F1 are the preparation of the full financial statements for a single company and the principal consolidated

More information

Implications of change in Government

Implications of change in Government Australia 92 outstanding tax and superannuation measures revisited by new Government Implications of change in Government Since the last update, Australia has had a change of Government. The centre-right

More information

Tax insights New Tax System for Managed Investment Trusts - Exposure Draft

Tax insights New Tax System for Managed Investment Trusts - Exposure Draft 20 April 2015 2015/6 Tax insights New Tax System for Managed Investment Trusts - Exposure Draft Snapshot On 9 April 2015 the government released Tax Laws Amendment (New Tax System for Managed Investment

More information

EXPLANATORY NOTES. 1. Summary of accounting policies

EXPLANATORY NOTES. 1. Summary of accounting policies 1. Summary of accounting policies Reporting Entity Taranaki Regional Council is a regional local authority governed by the Local Government Act 2002. The Taranaki Regional Council group (TRC) consists

More information

Capital Return ATO Class Ruling received

Capital Return ATO Class Ruling received ABN 47 116 648 956 ASX Announcement 5 December 2012 Capital Return ATO Class Ruling received Chalice Gold Mines Limited (ASX: CHN/TSX: CXN) advises that the Australian Taxation Office ( ATO ) has today

More information

MALTA: A JURISDICTION OF CHOICE

MALTA: A JURISDICTION OF CHOICE MALTA: A JURISDICTION OF CHOICE LONDON - September 2012 Doing business from Malta can make a huge difference for your business UHY BUSINESS ADVISORY SERVICES LIMITED Updated September, 2012 An attractive

More information

Australian tax booklet for International (US-domiciled) ishares ETFs

Australian tax booklet for International (US-domiciled) ishares ETFs Australian tax booklet for International (US-domiciled) ishares ETFs 1. Introduction 1.1 The Australian Tax Booklet for International ishares Funds ( Booklet ) provides a general summary of the main Australian

More information

NEW ZEALAND International Comparison of Insurance Taxation January 2005

NEW ZEALAND International Comparison of Insurance Taxation January 2005 International Comparison of Insurance International Comparison of Insurance New Zealand General Insurance 1 Definition Definition of property and casualty insurance company A company to which insurance

More information

EXPLANATORY NOTES ON THE CRITICAL TAX ISSUES FOR THE OPERATION OF BANK HOLDING COMPANY STRUCTURE IN NIGERIA

EXPLANATORY NOTES ON THE CRITICAL TAX ISSUES FOR THE OPERATION OF BANK HOLDING COMPANY STRUCTURE IN NIGERIA NIGERIA INFORMATION CIRCULAR Published: April, 2012 Subject: EXPLANATORY NOTES ON THE CRITICAL TAX ISSUES FOR THE OPERATION OF BANK HOLDING COMPANY STRUCTURE IN NIGERIA This circular is made to address

More information

Bills Digest No. 68 2001 02

Bills Digest No. 68 2001 02 Department of the Parliamentary Library IN FORM ATION AND R ESEARCH S ERVICES Bills Digest No. 68 2001 02 New Business Tax System (Debt and Equity) Bill 2001 ISSN 1328-8091 Copyright Commonwealth of Australia

More information

2015 YEAR END TAX & SUPERANNUATION PLANNING GUIDE

2015 YEAR END TAX & SUPERANNUATION PLANNING GUIDE 2015 YEAR END TAX & SUPERANNUATION PLANNING GUIDE We are pleased to provide our year end tax planning guide for 2015. Tax Planning should be done on a regular basis throughout the year. However, these

More information

ATO CLASS RULING PUBLISHED

ATO CLASS RULING PUBLISHED 10 December 2014 ATO CLASS RULING PUBLISHED Syrah Resources Limited (ASX: SYR) advises that the Australian Taxation Office ( ATO ) has today published a final Class Ruling () in relation to the Company

More information

Taxation treatment of exchange traded futures

Taxation treatment of exchange traded futures Taxation treatment of exchange traded futures 20 May 2010 Alison Noble, Principal, Deloitte Touche Tohmatsu Ltd Christopher Neil, Analyst, Deloitte Touche Tohmatsu Ltd The views in this document are those

More information

UNITED KINGDOM LIMITED LIABILITY PARTNERSHIPS

UNITED KINGDOM LIMITED LIABILITY PARTNERSHIPS UNITED KINGDOM LIMITED LIABILITY PARTNERSHIPS Background A United Kingdom Limited Liability Partnership (LLP) has become a very popular vehicle for international commercial activity. This is because the

More information

HOLLY SPRINGS INVESTMENTS LIMITED HALF YEAR REPORT FOR THE SIX MONTHS ENDED 30 SEPTEMBER 2008 CONTENTS STATEMENT OF FINANCIAL PERFORMANCE 1

HOLLY SPRINGS INVESTMENTS LIMITED HALF YEAR REPORT FOR THE SIX MONTHS ENDED 30 SEPTEMBER 2008 CONTENTS STATEMENT OF FINANCIAL PERFORMANCE 1 HALF YEAR REPORT FOR THE SIX MONTHS ENDED 30 SEPTEMBER 2008 CONTENTS PAGES STATEMENT OF FINANCIAL PERFORMANCE 1 STATEMENT OF MOVEMENTS IN EQUITY 2 STATEMENT OF FINANCIAL POSITION 4-4 STATEMENT OF CASH

More information

International trends in dividend taxation. Implications for Australian Companies and Tax Policy. Report prepared for the ASX

International trends in dividend taxation. Implications for Australian Companies and Tax Policy. Report prepared for the ASX International Tax Services EYEcon October 2002 International trends in dividend taxation Implications for Australian Companies and Tax Policy Report prepared for the ASX Table of Contents Overview...ii

More information

GUIDE TO FRS 102 DISCLOSURE

GUIDE TO FRS 102 DISCLOSURE GUIDE TO FRS 102 DISCLOSURE in Relate Accounts +353 1 4597800 +44 871 284 3446 info@relate-software.com www.relate-software.com ROI R005 CONTENTS Relate Accounts Introduction...4 Background...4 The Future

More information

Tax Consolidation Accounting

Tax Consolidation Accounting Compiled Interpretation Interpretation 1052 Tax Consolidation Accounting This compiled UIG Interpretation applies to annual reporting periods beginning on or after 1 January 2011. Early application is

More information

Abbey plc ( Abbey or the Company ) Interim Statement for the six months ended 31 October 2007

Abbey plc ( Abbey or the Company ) Interim Statement for the six months ended 31 October 2007 Abbey plc ( Abbey or the Company ) Interim Statement for the six months ended 31 October 2007 The Board of Abbey plc reports a profit before taxation of 18.20m which compares with a profit of 22.57m for

More information

ON THE SCALES 2 OF 2012 NATIONAL BUDGET 2012

ON THE SCALES 2 OF 2012 NATIONAL BUDGET 2012 ON THE SCALES 2 OF 2012 NATIONAL BUDGET 2012 On 22 February 2012 the Finance Minister, Pravin Gordhan delivered his National Budget Speech. Whilst we have demonstrated resilience in the face of global

More information

TAX TIME MONTHLY MAY 2016 INCOME TAX SUPERANNUATION GOODS AND SERVICES TAX STATE TAXES. Hall Chadwick

TAX TIME MONTHLY MAY 2016 INCOME TAX SUPERANNUATION GOODS AND SERVICES TAX STATE TAXES. Hall Chadwick TAX TIME MONTHLY MAY 2016 INCOME TAX SUPERANNUATION GOODS AND SERVICES TAX STATE TAXES +61 2 9263 2600 www.hallchadwick.com.au Hall Chadwick CONTENTS INCOME TAX 1 2016 Budget only low income Medicare Levy

More information

Understanding tax Version 5.0

Understanding tax Version 5.0 Understanding tax Version 5.0 This document provides some additional information to help you understand the financial planning concepts discussed in the SOA in relation to tax. This document has been published

More information

INTERNATIONAL TIDBIT: Reporting Foreign Investments New Requirements for the 2013 Tax Year

INTERNATIONAL TIDBIT: Reporting Foreign Investments New Requirements for the 2013 Tax Year INTERNATIONAL TIDBIT: Reporting Foreign Investments New Requirements for the 2013 Tax Year The last few years have seen increased emphasis on individuals reporting about their foreign investments and penalizing

More information

Invesco Funds. Société d investissement à capital variable (SICAV) United Kingdom Country Supplement. 22 August 2016

Invesco Funds. Société d investissement à capital variable (SICAV) United Kingdom Country Supplement. 22 August 2016 Invesco Funds Société d investissement à capital variable (SICAV) 22 August 2016 This United Kingdom country supplement forms part of and should be read in conjunction with the Prospectus of Invesco Funds,

More information

TAXATION STATEMENT GUIDE 2015

TAXATION STATEMENT GUIDE 2015 INFIGEN ENERGY TAXATION STATEMENT GUIDE 2015 Infigen Energy comprises the following: Infigen Energy Limited (ABN 39 105 051 616) Infigen Energy (Bermuda) Limited (ARBN 116 360 715) Infigen Energy Trust

More information

Heads Up Presentation of Research & Development (R&D) tax offset

Heads Up Presentation of Research & Development (R&D) tax offset Assurance & Advisory Issue: 2014/02 2 May 2014 Heads Up Presentation of Research & Development (R&D) tax offset Background Guidance in Accounting Standards Presentation choices and impact on financial

More information

Tax facts & figures New Zealand

Tax facts & figures New Zealand Tax facts & figures New Zealand 2013 New Zealand Tax facts & figures 2013 For the latest information on developments in tax law and policy visit our web site at: pwc.co.nz New Zealand Tax facts & figures

More information

Taxation Treatment of Futures

Taxation Treatment of Futures Taxation Treatment of Futures October 2003 Any queries regarding this paper can be directed to Patrick Broughan, Taxation Partner Ernst & Young, Melbourne on (03) 9288 8830 IMPORTANT DISCLAIMER Ernst &

More information

Taxation. General. 1. Taxation UK. Mondi plc Ordinary Shareholders

Taxation. General. 1. Taxation UK. Mondi plc Ordinary Shareholders Taxation The statements set out below are intended only as a general guide to United Kingdom ( UK ) and South Africa ( SA ) current law and practice and apply only to certain categories of person who are

More information