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Our dedicated international tax professionals assist our clients with their cross-border tax structuring, planning, reporting and risk management.
Our market-leading global tax desk network - a co-located team of highly experienced professionals from multiple countries - has revolutionised the way we provide international tax services. We work with you to build proactive and truly integrated global tax strategies that address the tax risks of today's businesses and achieve sustainable growth.
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Australia’s Adoption of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI)
This Global Tax Alert outlines in detail Australia’s plans to adopt MLI Articles including reserving the right to adopt provisions with regard to the artificial avoidance of PE status in bilateral treaties. In addition, Australia expressly excluded cases involving its general anti-avoidance provisions (e.g., Diverted Profits Tax and Multinational Anti-Avoidance Law) from the scope of the mandatory binding treaty arbitration (MAP) procedures.
On 7 June 2017, Australia and New Zealand participated in the signing ceremony of the Multilateral Convention (MLI) to start the process to implement certain BEPS measures to update the existing network of bilateral double tax treaties. The Australian Government confirmed its adoption positions and reservations on a provisional basis but noted that the MLI will require various processes before it becomes effective - in our view the operation of the MLI changes is therefore unlikely before 2019.
Australia's Diverted Profits Tax Bill: includes updated transfer pricing guidelines and increased penalties
Australian and multinational significant global entities will be affected by a Bill introduced into Parliament on 9 February 2017.