Australia

Trust law bites back against the Australian Tax Office

The recent decision of the Full Federal Court of Australia in Thomas v Commissioner of Taxation1 is a timely reminder of two points: tax results are often dictated by the rules of the non-tax world, and even unattractive cases sometimes win. … Continue reading

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Filed under Australia, Tax

Australian Tax Office takes action on assurance for Private Groups

The Australian Tax Office’s ("ATO") focus on large privately owned and wealthy groups ("Private Groups") is in full swing with no sign of slowing down in the 2017 year. With the top 320 large Private Groups holding A$112 billion of net … Continue reading

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Filed under Australia, Tax, Uncategorized

Is a register of beneficial ownership of companies coming?

As part of the global transparency push, the G20 has committed to implement rules requiring the disclosure of beneficial ownership of legal entities (in addition to automatic exchange of financial account information and the BEPS related transparency measures). On 13 … Continue reading

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Filed under Australia, Offshore, Private wealth and trusts

Tax transparency – a looming issue for Private Groups?

In efforts to increase the “public awareness of corporate tax issues,” tax transparency has been a popular policy option to “maintain public pressure on aggressive tax practices”. Whilst the focus has typically been on large multinationals, broader tax transparency measures … Continue reading

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Private Groups attracting ATO attention

The ATO has once again shown Private Groups that it is committed to greater transparency – however only this time, it is the ATO that is being transparent. Late last week, the ATO released a list of behaviours, characteristics and … Continue reading

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Tax Adviser or Australian Taxation Office Informer? The Mandatory Disclosure Proposal

As part of the 2016-17 Federal Budget, the Government announced that it will introduce Mandatory Disclosure Rules to require tax advisers (and in certain circumstances taxpayers) to report ‘aggressive tax arrangements’ to the Australian Taxation Office ("ATO"). At the same … Continue reading

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Australian Federal Budget 2016 – Some reflections for large private groups and HNWIs

The 2016-17 Australian Federal Budget confirms that the Australian Taxation Office (ATO) will continue to be heavily focused on the tax affairs of private groups and high net worth individuals (HNWIs) (and their tax advisors).  However, there will be some … Continue reading

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Australia introduces a new 10 per cent withholding obligation on purchasers of Australian real property from foreign residents

Amendments to Australian tax law have imposed a new 10 per cent non-final withholding obligation on the purchaser of interests in Australian real property (whether direct or indirect) when acquired from a foreign resident. The new measures will generally apply … Continue reading

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Hong Kong Court refused to make a grant of administration ad colligenda bona for lack of special circumstances and special justification

In Re Oung Chi Lian Fang (HCMP2347/2015), the Hong Kong High Court refused an ex parte application for a grant of administration ad colligenda bona under s.36 of the Probate and Administration Ordinance. Introduction Ad colligenda bona grants are temporary … Continue reading

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Filed under Australia, Hong Kong and Singapore, London, Offshore, Private wealth and trusts