Taxation of Offshore Operations (LAWS6129)


This unit examines Australia┬┐s rules for taxing the income earned from offshore operations. The unit examines the taxation of conducting business and holding investments offshore through foreign branches, companies, trusts, partnerships, and hybrid entities. It also examines the repatriation of profits from these entities, the treatment of the cost of financing these operations and the consequences of offshore reorganisations and relocations. The unit examines in detail Australia┬┐s CFC rules, transferor trust regime, the FITO regime, thin capitalisation rules and foreign hybrid rules.

Our courses that offer this unit of study

Further unit of study information


1x2-hr lecture/week


assignment (30%) and 2hr exam (70%)

Faculty/department permission required?


Unit of study rules

Assumed knowledge

It is assumed that students undertaking this unit have an understanding of Australian income taxation law commensurate with that which would be obtained from completing undergraduate study in Australian taxation law or five years working with Australian tax law in a law or accounting practice, in an industry role or in the Australian Taxation Office. For students who do not have such knowledge or work experience, they first should undertake LAWS6825 Introduction to Australian Business Tax before enrolling in this unit.

Study this unit outside a degree

Non-award/non-degree study

If you wish to undertake one or more units of study (subjects) for your own interest but not towards a degree, you may enrol in single units as a non-award student.

Cross-institutional study

If you are from another Australian tertiary institution you may be permitted to underake cross-institutional study in one or more units of study at the University of Sydney.