OECD Inclusive Framework Reaches Consensus on Pillar Two “Side by Side” Package

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Australia Tax News

Business income of foreign hybrid exempt

7 October 2008
Draft legislation on State Bonds withholding tax exemption

30 August 2008
Capital gains participation exemption clarified

30 August 2008
Discussion draft on New Art. 7 of OECD Model – details

30 August 2008
OECD Council approves 2008 Model Tax Convention

11 August 2008
Determination on interaction between transfer pricing and debt/equity rules finalized

11 August 2008
Treaty between New Zealand and Australia – developments

11 August 2008
Australian Taxation Office – Delaware LP is foreign hybrid

27 July 2008
Comments on draft contents of 2008 update to Model Tax Convention published

27 July 2008
Treaty between India and Australia – Indian ruling on taxability of project monitoring services rendered by Australian company with PE in India

21 June 2008
Reform of anti-deferral regimes – Issues Papers released

21 June 2008
Treaty between Australia and Ireland – ATO: Irish Common Contractual Fund not treaty resident

21 June 2008
Draft of 2008 Model Tax Convention – Proposed changes to Commentary to Art. 12 (definition of royalties)

21 June 2008
Foreign investment rules to be amended

14 May 2008
Draft ruling of taxation of ship and aircraft leasing profits

14 May 2008
Treaty between the Netherlands and Australia – negotiations

14 May 2008
Treaty between Australia and South Africa – new protocol signed

14 May 2008
Treaty between Australia and US – No treaty relief for US tax paid

14 May 2008
Withholding tax on payments from managed funds to be halved

16 March 2008
Treaty between Australia and Japan – details

16 March 2008
CFC attribution based on de-facto control test clarified

16 March 2008
ATO decides Dutch pension fund constituted as Stichting is trust

8 February 2008
Treasury invites comments on future tax treaties

8 February 2008
High Court decision on Australia-New Zealand tax treaty

8 February 2008
OECD released discussion draft on transactional profit methods

8 February 2008
Treaty between New Zealand and Australia – negotiations

8 February 2008
Treaty between Australia and United Kingdom – ATO interprets by reference to LOB provision in treaty between Australia and United States

8 February 2008
Interaction between thin capitalization and transfer pricing rules

16 January 2008
Treaty between Norway and Australia – erratum

3 December 2007
Treaty between Australia and Finland enters into force

3 December 2007
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