Public Consultation on the Multinational Anti‑avoidance Law
The Australian government also announced a public consultation on its Multinational Anti-avoidance law on May 12, 2015:
“In the 2015-16 Budget, the Government announced that it would introduce the tax integrity multinational anti‑avoidance law to stop multinational entities using artificial or contrived arrangements to avoid a taxable presence in Australia.
This exposure draft Bill and associated explanatory material would amend the anti-avoidance rules in Part IVA of the Income Tax Assessment Act 1936, giving effect to that decision.
The measure is intended to target situations in which:
- a foreign multinational supplies goods or services to Australian customers and books that revenue offshore;
- the activities of an Australian entity are integral to the Australian’s customer’s decision to purchase the goods or services;
- the profits from Australian sales are subject to low or no global tax; and
- one of the principal purposes of the arrangements is to obtain a tax benefit.
Where the measure applies, the Commissioner of Taxation may cancel the Australian tax benefits obtained in connection with the scheme.
This measure will only apply where the non-resident’s annual global revenue is greater than $1 billion.”
See the complete release here.
The Exposure Draft is available here.
The Explanation Material is available here.
Closing date for submissions is set to Tuesday, 9 June 2015.
Robert Robillard, Ph.D., CPA, CGA, MBA, M.Sc. Econ.
Senior Partner, DRTP Consulting Inc.
514-742-8086; robertrobillard “at” drtp.ca
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