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Review of international tax arrangements.



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NO.021

REVIEW OF INTERNATIONAL TAX ARRANGEMENTS

I am announcing today details of a review of international tax arrangements with particular attention to be given to whether current international tax arrangements impede Australian companies expanding offshore, whether they impede attraction of domestic and foreign equity, and how they affect holding companies and conduit holdings being located in Australia. The Review will concentrate on at least four principal areas:

the dividend imputation system's treatment of foreign source income Australian companies can currently provide imputation credits to their shareholders in respect of Australian, but not foreign, company tax paid. The review will examine business concerns with the imputation "bias" against foreign source income;

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the foreign source income rules (comprising principally of the controlled foreign corporation (CFC), foreign investment fund (FIF) and the foreign tax credit/exemption rules) the review will examine claims that the rules are complex and impose significant compliance costs on business, are out of step with modern business practice, and

negatively affect decisions to locate in Australia vis-a-vis countries with less stringent or no such rules;

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the overall treatment of `conduit income' `conduit' taxation rules concern the treatment of foreign source income flowing through an Australian entity (companies and managed funds) to non-resident investors. The review will examine the adequacy of the current conduit rules and their impact on the establishment of regional holding companies and managed funds (with an international clientele) in Australia; and

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high level aspects of Double Tax Agreement (DTA) policy and processes in light of the recent agreement with the US and the ongoing negotiations with the UK, the review will examine Australia's DTA policy and related aspects of the domestic tax law as they relate to the balance between residence and source taxation.

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The Treasury is preparing a paper for public release around mid-year to serve as a basis for consultations. I have asked the Board of Taxation to undertake public consultations on these issues in the second half of this year and provide the Government with a report by the end of the year. This timing takes account of the immediate priorities of both the Government and business sector in implementing existing tax reforms, such as consolidation for wholly-owned corporate groups, which comes into effect on 1 July 2002.

The review will build on the progress made by the delivery of an internationally competitive company tax rate of 30 per cent, the introduction of GST in place of wholesale sales tax and inefficient transaction taxes, the successful negotiation in late 2001 of changes to the Australia/United

States Double Tax Convention.

CANBERRA

2 May 2002

© Commonwealth of Australia 2000