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ATO Issues Tax Alerts Concerning Transactions with Offshore PEs, GST Avoidance, and Treatment of Debt as Equity under Thin Cap Rules

12 August 2016

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Approved Changes

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Australia

On 10 August 2016, the Australian Taxation Office (ATO) issued tax alerts on arrangements currently being targeted for review. Links to the alerts and summaries of the targeted arrangements are as follows. TA 2016/7 - Arrangements involving offshore permanent establishments The ATO is reviewing arrangements involving tax-consolidated groups with subsidiaries using offshore permanent establishments (PE) that have entered into intra-group transactions. In particular, the ATO is looking at transactions where the amount of taxable income returned does not reflect the economic substance and significance of the operations carried on in and between Australia and the offshore jurisdiction. TA 2016/8 -...