Australia : regional tax minimization

Journal
Kellock, I.
Australia
Asia-Pacific Tax Bulletin 2007 (Volume 13), No. 3
PriceUSD 45

This article first considers supply chain planning, including manufacturing in Australia, permanent establishment issues, tax issues on restructuring to implement a tolling/contract manufacturing structure, and transfer pricing issues. Then it considers the key issues in considering a structure that increases leverage in Asutralia: deductibility of interest and thin capitalization rules.