This presentation will consider the recent updates impacting how large corporates determine the tax residency of their subsidiaries including:
- • The ATO’s public guidance on central management and control in TR 2018/5 and PCG 2018/9;
- • The Multilateral Instrument (MLI) and how it is impacting the residency outcomes under Australia’s treaties;
- • How large Australian-headquartered corporates are managing the tax residency of subsidiaries as part of their global group; and
- • The recommendations from the Board of Taxation's review of corporate tax residency.