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Embedded royalties in payments under cross-border supply contracts

Australia - November 23 2018 The Commissioner issued Taxpayer Alert TA 2018/2 on 20 November 2018. This alert raises his concerns with arrangements involving the supply of…

Is your profit margin on the ATO’s radar? Transfer Pricing & Inbound Distributors

Australia - November 29 2018 On 23 November 2018, the Commissioner issued Draft Practice Compliance Guide 2018/D8 (PCG 2018/D8) outlining his compliance approach to the transfer…

Corporate tax disclosure and transparency and exemption for Australian owned private companies

Australia - November 22 2015 In the week commencing 14 December 2015, the Commissioner will release the first tax transparency report disclosing certain tax information of public…

Proposed tax changes to Managed Investment trusts

Australia - September 15 2015 The Commonwealth Government announced in its recent Budget 2015-16 that it will be proceeding with the implementation of a new tax system for…

GST and supply of real property & real property leases - the High Court’s decision in MBI Properties

Australia - January 22 2015 On 3 December 2014, the High Court handed down its decision in Commissioner of Taxation v MBI Properties Pty Ltd [2014] HCA 49 (MBI Decision). This…