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Bookmark or Share- Hybrid mismatch rules for privately owned and wealthy groupsEnacted in 2018, the hybrid mismatch rules aim to prevent multinational companies and privately owned groups from gaining an unfair competitive advantage by avoiding income tax or obtaining double tax benefits through hybrid mismatch arrangements. These arrangements exploit differences in the tax treatment of an entity or instrument under the ...
- Income from overseas branches for privately owned and wealthy groupsWe focus on an Australian company’s overseas branch or permanent establishment income that has been incorrectly recognised as non-assessable non-exempt (NANE) branch income under section 23AH of the ITAA 1936. We also focus on the deductions being claimed to have been incurred by the Australian company in deriving section 23AH NANE branch ...
- Controlled foreign entities for privately owned and wealthy groupsthe controlled foreign company (CFC) or transferor trust (TT) is in an unlisted country. there is a failure to disclose all interests in CFCs, TTs or other foreign entities. there is a failure to lodge an international dealings schedule, despite disclosing an interest in a CFC, TT or another foreign entity in the tax return.
- Thin capitalisation for privately owned and wealthy groupsThe thin capitalisation rules apply to most multinational businesses operating in Australia. This includes privately owned entities that are foreign controlled or have overseas entities, with more than $2 million in debt deductions, on an associate inclusive basis. The old thin capitalisation rules continue to apply to Australian plantation ...
- Significant global entities and country-by-country reporting entities ...Significant global entities and country-by-country reporting entities for privately owned and wealthy groups. Entities that met the definition of SGE or CBC reporting entity but failed to self-assess as one attract our attention.
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