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27 Jul 2022 1 min read
‘Treaty shopping’ broadly involves corporate groups interposing related entities in DTA friendly jurisdictions to obtain a more favourable WHT rate than would have applied if a payment from Australia were received directly by the ultimate recipient, in a country with no or a less favourable DTA with Australia.
The ATO will engage with taxpayers and advisers to scrutinise existing and proposed arrangements exhibiting features outlined in TA 2022/2, and in appropriate circumstances penalise the taxpayer under Australian tax laws, including using the “Part IVA” general anti-avoidance rules and/or diverted profits tax rules.
If you have entered into, or are contemplating entering into, an arrangement of this type, we encourage you to discuss your situation with your Grant Thornton contact.
New Payday Super legislation addresses concessional contributions cap issues for 2026/27, but salary sacrifice and early payments remain key concerns.
The Government has introduced legislation for a minimum 30% tax on discretionary trusts from 1 July 2028. While some stakeholder feedback has been adopted, significant concerns remain around flexibility, complexity and the impact on private groups and SMEs.
Learn about the Federal Court decision around car parking fringe benefits for employers outside the CBD areas. Discover our recommendations in light of this decision. Stay informed to ensure accurate FBT returns in 2027.