STS-TAX 发表于 2012-10-25 14:25
ATO HAS FOREIGN CONTROL TEST
http://www.ato.gov.au/taxprofessionals/content.aspx?menuid=0&doc=/cont ...
3IX37 发表于 2012-10-25 15:28
I believe it is treated as a controlled foreign company (CFC), under the de minims exception, attrib ...
STS-TAX 发表于 2012-10-25 13:25
ATO HAS FOREIGN CONTROL TEST
http://www.ato.gov.au/taxprofess ... uid=0&doc=/cont ...
maniwood 发表于 2012-10-25 14:48
where I can find the info in ATO? do you have any link I can have a look? As my understanding, our ...
3IX37 发表于 2012-10-25 14:28
I believe it is treated as a controlled foreign company (CFC), under the de minims exception, attrib ...
3IX37 发表于 2012-10-25 14:58
haha, I just noticed that you mentioned Google.
This is a very good case, which currently under ...
3IX37 发表于 2012-10-25 16:52
I am always amazed by how fast some people can response on this forum. Sometimes i wonder whether th ...
taxbreak 发表于 2012-10-25 15:06
This test is to test income flowing into Australian entities not income flowing overseas.
STS-TAX 发表于 2012-10-25 16:23
Controlled foreign company
A controlled foreign company is a non-resident company controlled by an ...
3IX37 发表于 2012-11-4 11:56
Sri Lanka is a treaty country. it however is not a listed country, instead it is one of section 40 ...
640 发表于 2012-11-23 09:51
Can we just make it into a oversea loan, and pump up the expenses section instead?
taxbreak 发表于 2012-11-23 11:19
This is covered by the Thin Capital Provisions. You can not deduct all the interest if you debt ra ...
640 发表于 2012-11-23 09:51
Can we just make it into a oversea loan, and pump up the expenses section instead?
3IX37 发表于 2012-11-23 11:45
Further to 34#,
i guess the thin cap is more likely than not to focus on Au sub or branch, who r ...
3IX37 发表于 2012-11-23 12:11
I don't think we can achieve any advantages by doing this.
Curent circumstance of LZ is
640 发表于 2012-11-23 11:15
Fair enough, so we also need a way to get the money back. How about another loan to a local AU sub ...
640 发表于 2012-11-23 11:15
Fair enough, so we also need a way to get the money back. How about another loan to a local AU sub ...
3IX37 发表于 2012-11-23 12:24
haha, good thinking.
However, ATO has its ultimate tool Division 13, it does not limit the inter ...
lee2267 发表于 2012-11-23 11:37
Transferring Price specialist 才能完全回答这方面的问题的哇。。别说人家4大还有专门的 department搞这个 ...
3IX37 发表于 2012-11-23 15:11
I totally agree and thanks for sharing.
Further to this article, it was written more likely from ...
xinxin119 发表于 2012-12-11 21:45
how do u make sure central control and management is still in aus if foreign corp trustee is appoi ...
xinxin119 发表于 2012-12-11 21:45
how do u make sure central control and management is still in aus if foreign corp trustee is appoi ...
3IX37 发表于 2012-10-31 23:35
This is totally not related to the original LZ's post.
In relation to your question regarding ho ...
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