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TABL2756 International Business Taxation

tag 0 Download 15 Pages / 3,536 Words tag 02-11-2020


You are required to advise a client who is an Australian company seeking to make a non-portfolio (direct) investment in a foreign jurisdiction which you select. You are required to explain details of your client's business and of the investment proposal.
You are free to choose any type of business proposal you like provided that the scenario which you choose raises issues in two or more of the following areas:
• tax considerations influencing the choice of international business structures
• financing of the operation
• utilising tax incentives
• double taxation relief (i.e. exemptions / foreign tax credits)
• withholding taxes
• taxation of business profits / permanent establishment
• application of double taxation agreements
• treaty shopping
• transfer pricing
• technology / IP transfer
You are required to advise your client as to the tax effects of the investment structure that you propose under both Australian law and the law of the foreign jurisdiction. You should also advise how you would recommend structuring the investment so as to achieve the best overall aftertax profit in both Australia and the foreign jurisdiction (subject to anti-avoidance provisions).
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Total 15 pages

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