International tax law was once the sexy end of the tax profession. That is, until Federal law enforcement agencies started kicking down doors and putting people in jail. At that point, the Men (who understand real international tax law) and the Boys (who merely pretend), started to get sorted out.
International tax law is not what you hear about at the Pub. It is not about secret credit cards and Swiss bank accounts. At its core, international tax is a very complicated, and often counter-intuitive area of international law. It represents the intersection between two or more independent legal systems vying for your money, overlayed by a nascent system of international norms and treaties.
The strange thing about this very complicated and little understood area of law is just how many people it effects. Australia is a very open economy, and a large proportion of our businesses and investors are plugged into the international community. Furthermore a huge number of people leave Australia to work overseas, as well as come to Australia from foreign places to live and work.
For this reason international tax advice and structuring forms a large part of our daily work. We have taken the time to properly understand its full implications.
Our advice and assistance regularly touches on issues including:
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Foreign income accrual measures (i.e. the CFC, FIF and transferor trust measures);
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The Australian tax consequences of repatriating and ultimately distributing foreign source income;
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Foreign income conduit rules, whereby foreign source income is ultimately distributed to foreign owners;
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The impact of Australia’s network of international tax treaties, and their use in avoiding double taxation;
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Transfer pricing and thin capitalisation; and
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Remuneration and in-bound and out-bound investment structuring for expatriates and foreign workers.
Please call us on 1300 654 590 to discuss any issues you may be facing in these areas.
