Non-final withholding tax on transactions involving taxable Australian property

On 31 October 2014, the Commonwealth Treasury released a discussion paper on design for implementing a 10 per cent non-final withholding tax. The tax will apply from 1 July 2016 on foreign residents’ disposal of certain ‘taxable Australian property’ (a 2013-14 Federal Budget measure).

Submissions closed on 28 November.

Commissioner’s transfer pricing ruling

On 12 November 2014 the Commissioner of Taxation published Taxation Ruling TR 2014/6: Transfer pricing - the application of section 815- 130 (relevance of actual commercial or financial relations in identification of arm's length conditions).

See our Tax Insights update for details.

G20 Communique and global taxation initiatives

The G20 Communique published following the Brisbane Leaders’ Summit of the Group of Twenty (G20) includes commitments on economic growth, infrastructure, trade, employment, energy, climate change and tax.

On tax, the G20 will look to ensure fairness of the international tax system and to secure countries’ revenue bases. It agreed that profits should be taxed where profitable economic activities take place and where value is created.

The G20 welcomed progress made on a number of initiatives, including the Base Erosion and Profit

Shifting (BEPS) Action Plan. It has committed to finalise work on the Action Plan in 2015 (including transparency of taxpayer-specific rulings found to constitute harmful tax practices) and endorsed the global Common Reporting Standard for the automatic exchange of tax information on a reciprocal basis. It has also invited developing countries to engage in the BEPS project so that their concerns can be addressed.

Further information on BEPS is available at

http://www.pwc.com/BEPS