Australia: Practice Statement PS LA 2014/2 released by the Australian Taxation Office
The Australian Taxation Office (ATO) released guidance on what the ATO expects taxpayers to prepare in order to comply with the transfer pricing laws and manage related risks on 17 December 2014. According to guidance 25% penalty applies and
See MoreAustralia: Taxation Ruling 2014/8 introduces by the Australian Taxation Office (ATO)
Taxation Ruling 2014/8 gives outlines on what needs to be included in the documentation if the taxpayer is to meet the standard of a "reasonably arguable position" and avoid penalties, and sets out five key questions for preparation of
See MoreFree Trade Agreement between Australia and Korea
On Friday, 12 December 2014, a free trade agreement (FTA) between Australia and Korea entered into force. The Korea-Australia Free Trade Agreement (KAFTA) supports one of the strongest and most complementary economic relationships in the
See MoreAustralia & Uruguay: TIEA entered into force
The Tax Information Exchange Agreement (TIEA) (2012) between Australia and Uruguay has entered into force on 1st July 2014. This treaty generally applies from 1 January
See MoreAustralia: New Taxation Ruling TR 2014/6 introduced by the Australian Taxation Office (ATO)
Taxation Ruling TR 2014/6 gives guidance on identifying situations where the form of commercial or financial relations differs from the substance and confirms the ATO's power to disregard and reconstruct transactions that lack economic substance.
See MoreAustralia and China confirm FTA agreement
Australia and China has confirmed the conclusion of a free trade agreement (FTA). If the agreement is fully implemented, it will enable a tariff-free access of 95% Australian goods exports to Chinese
See MoreAustralia: new tax treaty with Switzerland enters into force on 14 October 2014
Australia-Switzerland new tax treaty has entered into force on 14 October 2014. The treaty, which was signed on 30 July 2013, replaces the existing Australia-Switzerland tax treaty which was signed in 1980. The new treaty will encourage further
See MoreIncome Tax Treaty Negotiations between Australia and UAE
The progress of income tax treaty negotiations between Australia and U.A.E were discussed recently, between Australian Treasurer and United Arab Emirates minister of state for financial affairs, on following issues: trade and investment
See MoreDTA between Australia and Switzerland ratified by Australia
On 24th September 2014, Australia completed its domestic ratification procedures with respect to the DTA signed with Switzerland. Once in force and effective, the new treaty will replace with the treaty between Australia and Switzerland Income Tax
See MoreAustralia: Parliament changes thin capitalization rules
The Australian Parliament passed previously announced legislation on 25 September 2014 which includes changes to the thin capitalization rules, a rewrite of the exemption for foreign non-portfolio dividends received by Australian companies, and
See MoreThe amended protocol of AANZFTA has been welcomed by New Zealand
The signing of protocol to amend the Agreement Establishing the ASEAN-Australia-New Zealand Free Trade Area (AANZFTA) has been welcomed by the New Zealand. AANZFTA is Australia’s first multi-country FTA. It is the first time Australia and New
See MoreAustralia – Reduces safe harbor for thin capitalization
Australia recently reduced the safe harbor rule for thin capitalization limit from 75% to 60%, corporate groups may want to consider what steps to take with respect to their thin capitalization positions. With effect from 1 July 2014 the permitted
See MoreAustralia and Japan signed an agreement to promote economic relations
Australia and Japan signed an agreement to promote economic relations (EPA), in Canberra on 8 July 2014. The Australian Department of Foreign Affairs and Trade said that, “this is the most liberalizing bilateral trade agreement and if it is fully
See MoreAustria: Government accepts bill amending the Fiscal Criminal Act
The Austrian parliament accepted the bill amending the Fiscal Criminal Act 2014 on July 2014. The draft bill aims at finish the exercise of partial disclosures as the current rules allow taxpayers to benefit from a repeated voluntary disclosure
See MoreUruguay-Ratification of TIEA with Australia and Canada
The government of Uruguay has announced that it has ratified the tax exchange information agreements with Australia and Canada. The TIEA between Australia and Uruguay was signed on 10 December 2012. To terminate the agreement either party will have
See MoreSwitzerland–Australia: approved double taxation agreements
The lower house of parliament approved the nation’s double taxation agreement on 4 June 2014. The DTA will enter in to force after both countries have completed their respective domestic requirements and ratification by both
See MoreCanada -Australia ITT regarding income of employee on a short-term secondment
The Australian Taxation Office has published Interpretative Decision ATO ID 2014/20 on May 30, 2014 regarding the income of a non-resident individual engaged by a resident employer resident in Canada is taxable in Australia despite that the employee
See MoreAustralia Confirms Superannuation Tax Changes
A reform is to be undertaken of the taxation of excess superannuation contributions. Some taxpayers are paying contributions at a rate that is considered excessive by many people in Australia. Currently non-concessional contributions exceeding the
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