Tax Insight: ATO’s Taxpayer Alert on Treaty Shopping

By Toby Eggleston, Hugh Paynter, Professor Graeme Cooper The ATO has released a new Taxpayer Alert [TA 2022/2] on treaty shopping arrangements, in particular: “arrangements designed to obtain the benefit of a reduced withholding tax … rate … in relation to royalty or [unfranked] dividend payments from Australia.” Read more

The ‘gist’ of the GILTI rules is not quite right

By Ryan Leslie The ATO issued its final determination on whether the US GILTI rules ‘correspond to’ Australia’s CFC rules for the purposes of applying Australia’s anti-hybrid rules – the determination maintains the position outlined in draft in 2019 that the rules do not correspond meaning that hybrid-mismatches can be taken to exist even though … Read more