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| 08 Aug 2022

Employee share option plans – the top seven things startup companies should watch out for when making new grants

We outline our top seven tips for new grants under existing employee share option plans.

Tax| 05 Aug 2022

Financial Services in Focus – Issue 70

In this edition, we consider exposure draft legislation to adjust how faith-based super products are treated under the annual performance test, and much more.

Tax| 20 Jul 2022

Financial Services in Focus – Issue 69

In this edition, we consider new financial requirements for directors of CCIVs, updated guidance from AUSTRAC on transaction reporting, and much more.

Tax| 11 Jul 2022

Customs tariff concession dispute for driverless trains never seems to leave the station…

The Full Federal Court recently delivered its judgment following an appeal made by the Comptroller-General of Customs about the tariff of driverless trains.