International Tax

 
We combine practical experience with technical expertise to assist inbound and outbound multinational corporations and funds with their global tax planning, structuring, reporting, risk management and deal execution.

Our team has commercial and technical expertise, as well as an active involvement in the sector. Our capability in this area includes:

  • Transactions– providing advisory and tax due diligence services for mergers, acquisitions, divestments, joint ventures and equity investments.
  • Structuring– implementing and reviewing structures to achieve tax efficiencies, mitigate risks and align tax objectives with business strategies.
  • Compliance & Health Checks– ensuring that the complex array of compliance and reporting requirements are met, and reviewing and revalidating adopted tax positions.
  • Advisory– advising on a broad range of matters including transfer pricing, thin capitalisation, base erosion and profit shifting (BEPS), Multinational Anti-Avoidance Law (MAAL), Controlled Foreign Company (CFC) rules, diverted profits tax (DPT), General Anti-Avoidance Rules (GAAR) and promoter penalty laws.

We closely follow legislative and regulatory developments and are quick to communicate how these may impact clients.

Experience

  • Advising an offshore purchaser on the acquisition of an Australian retailer and manufacturer.
  • Advising a large Australian corporate entity on the Australian tax implications of cross-border transactions including royalties on intellectual property, withholding tax and dividends.
  • Advising a multinational group whether a Permanent Establishment exists in Australia.
  • Advising clients on the application of the MAAL.
  • Advising on transfer pricing issues and preparing transfer pricing documentation.
  • Advising on the application of tax consolidation to corporate groups that include foreign entities.
  • Advising a large multinational fund manager on the income tax issues for the fund manager and investors in capital protected products.
  • Advising on the tax issues arising from the reorganisation of the Australian operations of a German diversified group relocating its manufacturing operations offshore.
  • Reviewing and advising on the income tax issues associated with the financing strategies of a large multinational retailer and its associates.

Related thinking

Tax| 04 Mar 2024

US citizenship or assets? Don’t risk excess estate tax on your death

We delve into how being a US citizen affects taxes, cover transfer tax considerations for both US and non-US citizens and provide practical tips for reducing tax liabilities.

Tax| 30 Nov 2023

Hot property! Major NSW and Victorian tax measures to impact property funds

Property funds – and their investors – may now be exposed to state taxation in ways in which they would not previously have been exposed.

International Tax| 12 Sep 2023

Windfall Gains Tax is now live / 意外增值税(暴利税)制度

First announced on 15 May 2021 and then delayed 12 months, the Windfall Gains Tax commenced on 1 July 2023. Here is a refresher of how the WGT will apply, how much it will be, the relevant exemptions and our observations.

Tax| 22 Aug 2023

Payroll tax for medical and other healthcare practices: clarity at last, what do you need to do?

The State Revenue Office Victoria and Revenue NSW have now confirmed, in the recently issued Revenue Ruling PTA-04, that payroll tax may apply to payments made by medical practices to their practitioners.