If the only certain things in life are death and taxes; it could perhaps be said that the only certain thing in Australian tax is the ongoing evolution of the Commissioner's approach towards:
- • Cross-border financing transactions (including withholding taxes, guarantee fees, thin capitalisation, and interest free loans);
- • International corporate restructures;
- • Value chain structuring (including marketing hubs); and
- • Perceived "BEPS" activity and structures.
- This session is aimed at providing an update on the current state of affairs of the Commissioner's approach to administering income tax and transfer pricing rules as well as other international tax issues.