We are living in a post-GFC world where economies, trade, commerce and technology are rapidly changing. In this evolving environment, the question is whether the tax policies and rules should also change, and if so, how?
This paper unpacks this question by drilling into key BEPS issues, outlining the current state of play, examining viable reform options, and speculating how BEPS will affect the tax system in the future. It covers:
BEPS - What is it and what does it mean?
the international context
the Australian context and insights into the forging of the Australian Policy
possible BEPS-driven reform and implications for the taxpayers and the ATO.
Over the last twelve months a number of transfer pricing reforms have been legislated in Australia with prospective and retrospective impact. The aim of these reforms is to better align our laws with OECD international standards. They are also aimed at ensuring MNC’s pay an appropriate amount of tax in Australia and will feature in the Australian Government’s response to BEPS.
This paper covers:
overview of the new transfer pricing legislation
transactions and structures most impacted
increased disclosure and transparency
TP within a BEPs world – the next 12 months
implications for corporate governance and dispute resolution.
Thin capitalisation and debt financing - the state of play
In the May 2013 Federal Budget, the Government announced the most significant changes to the thin capitalisation rules since their commencement in 2001. It also announced certain related measures that intend to limit deductions for financing costs. This paper explores those announced changes and the potential implications. It covers:
This paper discusses medium term prospects for tax reform in Australia. Beginning with the 2009 Henry Review proposals for a future tax architecture, it reviews economic and other developments since that time, exploring their implications for reform opportunities over the next several years.This paper covers:
Australian tax policy in a changing economic setting