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Treasury decided to spring a very big surprise on multinationals in an Exposure Draft released on 16 March 2023. The Draft was expected to address the Government’s promise to reconceptualise the thin capitalisation safe harbour from a debt: asset ratio to a percentage of EBITDA, which it does (a detailed analysis will follow). The Draft … Read more
By Jinny Chaimungkalanont, Nick Heggart and Jonathan Wu Update: Interestingly, on 15 March 2023, the State Revenue Office of Victoria (SRO) announced that the position in Victoria has not changed, and the SRO will continue to apply the Victorian provisions to all foreign purchasers and absentee owners. Currently, duty is payable in NSW on the … Read more
Summary A Bill was introduced into Parliament on 16 February 2023 to give effect to two changes, both of which will restrict shareholders” access to franking credits. The measures affect special dividends occurring in conjunction with a capital raising and off-market share buy-backs undertaken by listed public companies. There has been some adjustment to the … Read more
By Jinny Chaimungkalanont and Mark Peters Revenue NSW has now published its long-awaited Revenue Ruling on declarations and acknowledgments of trust in light of the 19 May 2022 stamp duty reforms (see our notes on those reforms here). Although housed in the longstanding Revenue Ruling DUT031 Declaration of trust in an agreement for sale, that … Read more
By Toby Eggleston, Ryan Leslie, Nick Heggart and Graeme Cooper The OECD’s 2 Pillar project to redesign the architecture of the international tax system continues its slow and faltering progress. This Tax Insight summarises some of the recent developments, and their implications for Australian groups. Read more
By Toby Eggleston and Mark Peters In this episode Mark Peters and Toby Eggleston discuss the latest in the world of NSW stamp duty. A must listen for those in property and infrastructure. More details can be found on blog here. Read more
The Australian Treasury has released an Exposure Draft of legislation which will further curtail the ability of companies to frank distributions. If enacted in its proposed form it could well impact special dividends paid in conjunction with M&A transactions. Read more
By Ryan Leslie, Alistair Haskett and Graeme Cooper Summary One of the few tax surprises in the October 2022 Budget was the announcement that “the tax treatment of off-market share buy-backs undertaken by listed public companies” would be aligned “with the treatment of on-market share buy-backs.” Treasury has now released an Exposure Draft of the … Read more
